ML20236X383
| ML20236X383 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 07/14/1998 |
| From: | Michael Clark, Herrmann T POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20236X371 | List: |
| References | |
| GL-96-06, GL-96-6, [[::JAF-RPT-MULTI|JAF-RPT-MULTI]], JAF-RPT-MULTI-0, JAF-RPT-MULTI-02671, JAF-RPT-MULTI-2671, NUDOCS 9808070338 | |
| Download: ML20236X383 (57) | |
Text
7___-
i to JPN-98-034 New York Power Authority - James A. FitzPatrick
(
Response to Request for AdditionalInformation Regarding Generic Letter 96-06 t
l l
NYPA Report No. JAF-RPT-MULTI-02671 i
" Summary of Detailed Evaluation for NRC Generic Letter 96-06" Revision 2 July 14,1998 1
1 r
l 9808070338 980730 PDR ADOCK 05000333 P
____d
st.
NEW YORK POWER AUTHORITY JAMES A.
FITZPATRICK NUCLEAR POWER PLANT
SUMMARY
OF DETAILED EVALUATION FOR NRC GsNERIC LETTER 96-06 REPORT #:
JAF-RPT-MULTI-02671 REVISION DATE PREPARED BY:
REVIEWED BY:
l N'
2 7
/9 Terry J.
Herrmsnn Matthew Clark l
Af g [_
^
\\
i APPROVED:
bM0 QNInherys
/DANIEE K'.
RUDDY Director of Design Engineering l
)
l.
?
INTRODUCTION Generic Letter 96-06 (Ref. 1) " Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions" dated September 30, 1996 requires JAF to determine:
{
I (1) if containment air cooler cooling water systems are susceptible to either water hammer or two phase flow conditions during postulated accident conditions; (2) if piping systems that penetrate the containment are susceptible to thermal expansion of fluid so that ov, pressurization of piping could occur.
On October 27, 1996 the James A.
FitzPatrick plant entered al scheduled refueling outage. The NRC staff informed the utilities at an NEI meeting on October 29 that plants starting up p'rior to the 120 day (January 28, 1997) submittal to GL 96-06 must perform an operability determination pursuant to GL 91-18 for the. systems susceptible to the GL concerns.
In order to support this requirement, report # JAF-RPT-MULTI-02596 " Operability Assessment for NRC Generic Letter 96-06" was developed and issued on 12/2/96.
The 120 day response submittal to the NRC, dated January 27, 1997, presented the operability findings and committed to submittal of detailed analysis results to the NRC by May 27, 1997. The purpose of this report is to summarize the findings of the detailed analyses that were performed to evaluate GL 96-06 and to present recommendations for our long term corrective action position.
Revision 1 of this report provides:
a) additional information l regarding penetration X-18 based on a revision to SWEC report Ref.
20, and b) discussion on the basis for the conclusions reached under the System Safety Function Review section for penetration X-226.
Revision 2 of this report provides four main changes.
First, an evaluation was performed of the potential for waterhammer in the piping inside containment associated with the drywell coolers and any relevant consequences.
- Second, additional information was provided to eliminate the recommended design changes for thermal pressurization of penetrations X-224 and X-226.
- Third, recommendations to modify penetrations X-18 and X-19 were withdrawn.
Finally, an evaluation of the potential for thermal pressurization of the RBCLC lines that penetrate the primary containment was conducted.
Several minor typographical changes were also made.
Note that any accident sequences assume 10 minutes before any operator actions can be taken.
Page 2 of 40 l
t.
DISCUSSION ITEM 1 MATEREADOER OR TWO PHASE FLCM l
This issue is primarily concerned with safety-related containment l air coolers which are credited.for heat removal from containment during DBA conditions. The generic letter does point out, however, that water hammer in cooling water systems associated with non-safety related containment air coolers can also challenge containment integrity by creating a containment bypass flow path for interfacing safety related systems.
At JAF the containment air coolers of concern are the Drywell Coolers (68E-1A to -1D and 68E-3A to -3D). These units are non-l safety related and are not credited for heat removal from l
containment during DBA conditions, as' documented in' Design Basis Document DBD-068 "Drywell Ventilation and Cooling System".
In addition, the JAF IPE Level 2 containment analysis did not take credit for the use of the drywell coolers.
Engineering judgement i
estimated that the drywell coolers would not be expected to remain l
operational in a
severe accident environment (i.e.,
high containment pressures or temperatures).
Any potential use of the l
drywell coolers, if feasible, will involve a delay in drywell pressurization, or more
- likely, potential fission products l
scrubbing (by deposition) on the drywell cooling coils.
Use of l
the drywell coolers is beyond JAFs design and current licensing bases.
The cooling water system associated with the Drywell Coolers is the non-safety related Reactor Building Closed Loop Cooling (RBCLC) system (FM-15A & B).
There is a concern that during a Design Basis (Large Break)
LOCA or steam line break inside containment (Small Break LOCA) concurrent with a Loss of Offsite l
Power (LOOP), a potentially damaging waterhammer could occur in the drywell cooling system.
During this scenario RBCLC pump power is initially lost leading to flow stagnation in the piping and cooling coils.
Heatup caused by condensing steam on the outside of the cooling coils may lead to voiding in the tubes and neighboring portions of the system.
The expansion of steam and subsequent countercurrent flow with water in the horizontal pipe runs in the system creates the potential for a condensation-induced waterhammer.
This type of waterhammer tends to produce significant piping loads.
Alternately, upon restoration of the power to the pumps and restoration of flow to the system, rapid refilling of the voided lines can result in a potentially damaging waterhammer event.
This is discussed further under item 1; waterhammer or two phase flow, event class 3, trapped void collapse waterhammer.
A third possibility is that a LOOP will not occur and waterhammer could occur due to the increased temperature of the RBCLC fluid at locations where the pressure drops below the saturation Page 3 of 40 l
ressure of the fluid.
The hydrodynamic loads introduced by such a
waterhammer event could be substantial, challenging the integrity and function of the containment air coolers and the associated component cooling water system, and posing a challenge to containment integrity.
Failure of the RBCLC lines inside containment could represent a potential challenge to containment integrity if associated with a postulated single active failure of containment isolation l
valve (s).in that same penetration.
The RBCLC lines provide cooling water to the drywell coolers and Recirculation pump motors.
During normal operation this piping and their associated valves serve as pressure boundary isolation for the primary containment.
i The uncontrolled addition of additional inventory to containment resulting from a pre-existing leak could theoretically result in a higher containment pressure due to reduced containment airspace l
-volume and a potential release path through the RBCLC system.
i Because the total RBCLC fluid inleakage into primary containment from-these lines prior to the postulated event would be considered minor, impact on containment pressure was not considered further.
This was previously evaluated in JAFs response (Ref. 29) to NRC Bulletin 80-24.
JAFs response I
concluded that the potential for.s.ignificant inleakage to containment from a failed RBCLC line is mitigated by JPFs ability to detect and isolate inleakage.
Altran has performed an analysis, summarized in reference 24, which has concluded that a condensation-induced waterhammer will not occur within the portion of the RBCLC system that serves as the containment pressure boundary.
Single Failure Evaluation In light of the waterhammer mechanisms described in the following paragraph below, an assessment must be done to determine what failures needed to be considered in order to establish the bounding conditions for the analysis.
The reference 25 memo describes how single failure criterion is applied to JAF.
Fundamentally, the definition of single failure in JAFs licensing basis considers only active failures subsequent to the accident.
Single passive failures (e.g. pipe break) apply only to accident initiators.
Active failures are applicable to devices that must change state-(on/off, open/ closed, etc.) in order to perform a given function.
For the case under consideration, this would include:
containment isolation valve position changes drywell cooling damper position changes drywell cooling fans stopping with an energized bus or failing to re-start following a loss of power and subsequent Page 4 of 40 l
f.
re-energization of the safety busses
)
RBCLC pumps stopping with an energized bus or failing to re-I start following a loss of power and subsequent re-energization of the non-safety busses Failure of RBCLC head tank level makeup or level annunciators Failure of instruments which provide information on the j
status of containment or RBCLC system parameters
/
Failure of a single DC power supply (SECY-77-439 considers a short circuit in.an electrical bus a single failure)
Normally, non-safety-related equipment wouldn't be considered in the above list.
Even though this equipment is not qualified for the post-LOCA environment outside of containment, it is reasonable to expect that it will continue to operate most of the time for the short duration (several minutes to several hours)-
where operators are making decisions on whether to isolate the drywell coolers.
Regardless, from a containment dependability standpoint, the limiting single failure that could result in a loss of containment integrity must be identified.
If all the containment isolation valves are assumed to be capable of performing their isolation function, there is no bypass scenario on a failure of the RBCLC piping due to waterhammer.
If, however, we assume the single. failure directly affects the containment isolation valve closure for one or more isolation valves, any waterhammer event that causes a loss of piping integrity will result in loss of the containment isolation function in the affected lines.
Based on this, the limiting single failure would be a loss of a single DC power supply.
The containment isolation valves are designed to fail open on a loss of power.
A loss of a single DC power. supply will prevent the closure capability of up to five isolation valves.
This is because each drywell cooler and Reactor Recirculation pump / motor cooler is fed from one division of DC power.
The "A" side is fed from the " Red" bus and the "B"
side is fed from the " Blue" bus.
Physical Mechanism which challer.ges the design function:
Based on the reference 22 EPRI report, there are several waterhammer mechanisms that may be postulated to occur in the drywell cooling system.
The details of the waterhammer mechanisms differ from those that have been previously studied, principally in the method of void generation, system pressures and possible heatup of water slugs during transit through the hot cooling coils.
Most of these differences tend to mitigate the severity of the waterhammer loads over those encountered previously.
There are several attributes of the RBCLC system at JAF that mitigate the potential consequences of the postulated scenarios.
Page 5 of 40 l
t.
These include:
8 RBCLC pump coastdown following a LOOP contributes to maintaining a positive pressure and flow through the drywell cooling coils.
This will in turn tend to retard the onset of boiling and will tend to create a more even temperature distribution from the cooling coils through the outlet piping to the primary containment boundary.
Drywell cooling coils are at an elevation below most of the piping in the Reactor Building and the system is equipped with a " head tank" vented to atmosphere.
This elevation maintains static pressure of at least 36 psia (ref. 24) on both the inlet and discharge sides of the coils.
In addition to delay 1.ng the onset of boiling, any pressure spike in the coils will result in collapsing the steam voids leaving the coils, having a limited tendency to continually replenish the water column because of gravity feed..This is because steam will flow up (out of the primary containment) on the discharge side and water will be forced to flow down (into primary containment) on the inlet side due to check valves on the inlet piping outside primary containment.
Drywell cooling coils are not designed to work as steam condencing units.
The presence of finned tubes designed for gaseous flow on the externa 1' surface will inhibit the removal of condensate from the surface of the tubes.
This in turn will inhibit the heat transfor rate because the condensate begins to act as an insulator to the heat transfer across the tubes.
This will be particularly true in the center of the coil.
As this was difficult to quantify, the analytical model conservatively did not take credit for this effect.
The reference 23 NUREG identifies six specific mechanisms or transient scenarios that can lead to unanticipated waterhummers.
A review of the Various Waterhammer types provided in NUREG/CR-5220 has been performed relative to JAFs DW Coolers.
A summary for each event class follows.
Severity classification is based on Table 3.2 of NUREG/CR-5220.
J 1.
Subcooled Water Slug
[Severicy - minor to severe) l Per the reference 22 EPRI report, "This wa terhammer event produces significant piping loads, but requires special conditions to exist.
Slowly filling a horizontal pipe leading to a reservoir of high pressure steam may permit rapid condensation and steam counterblow, causing slug formation and severe waterhammer in the horizontal section of pipe. "
According to the reference 23 NUREG, this event l
class of waterhammers typically occurs in PWR feedwater I
systems and steam generators and has been postulated to occur in Main Steam lines of BWRs and PWRs following an overfi11 event.
Again, it " requires a large area of steam Page 6 of 40 l
and subcooled water contact... Typically, this arises due to a small flow of subcooled water into a horizontal pipe f
leading to a reservoir of high pressure steam. "
It also requires steam at a high pressure relative to and acting on water that is significantly subcooled relative to the steam.
During the boiling process in the fan cooler coils, the presence of subcooled water in the piping headers could create a potential for steam-water counterblow to occur resulting in a condensation-induced waterhammer.
From tests conducted by Bjorge and Griffith cited by the EPRI report, a water slug is formed "when the local steam velocity becomes high enough to cause transition from
)
stratified flow to slug flow".
In terms of inlet-water flow rate for line. filling, the region of condensation-induced waterhammer in horizontal pipes experiencing the countercurrent flow of steam and subcooled water is. bounded by the absolute stability limit.
The lower limit of the water flow "is derived based on the fact that a very slow i
refilling process will result in bringing tbn water to saturation temperature as the pipe is being filled.
The avoidance of waterhammer is a result of the lack of sufficient condensation of the water surface. "
This type of event is not capable of occurring at JAF because the following " Event Scenario" does not provide the mechanism required to generate a waterhammer event.
Refer to Attachment 2 for figures that show a drawing of the RBCLC and drywell cooling systems along with piping lengths and elevations, cooling coil arrangement, subcooling graphs, etc.
These are taken from the reference 24 report.
Void Formation When the RBCLC pumps trip due to a LOOP or a postulated failure of the feeder breaker to the 10300 or 10400 bus, the pressure in the drywell piping is significantly reduced.
The saturated steam environment resulting from the LOCA enters the DW cooler housing initially because the fans continue to run (other than for a brief time while the emergency bus is energized) until they trip on motor overload caused by the high drywell (DW) pressure.
The majority of the heat will be added to the RBCLC water through the drywell coolers and through the uninsulated piping during this time.
The heat addition will tend to cause a natural circulation of the water in the drywell coolers with the water in the supply side piping.
Density differences and the piping configuration (including check valves on the supply piping) cause this circulation.
The water in the drywell coolers will begin to boil when its temperature exceeds the saturation temperature for Page 7 of 40 l
i*
the static system pressure.
When this boiling occurs,.the cooler will begin to void and expel hot j
water in to the supply side piping.
Slug Formation The hot water will mix with return piping water and increase its temperature.
Eventually steam will begin. leaving the drywell coolers and enter the return piping.
The steam bubbles will rise and condense in the vertical riser and return lines.
Water will not recirculate from the return end because of the check valves in the piping.
Initially, the subcooling in the vertical section will be greater than 70*F.
This large subcooling margin will result in significant condensation.
The pressure pulses that result from the steam bubbles condensing in the vertical section will be small in magnitude; these are typically referred to as noise and are not of significance.
The steam will eventually break through the vertical section'and reach the horizontal segments of piping.
This horizontal run was divided into several sections for analysis purposes.
When steam reaches the initial segment, the temperature of the water is low enough to condense the steam but not high enough to generate condensation-induced waterhammer.
This is because these types of waterhammers require a subcooling margin of 36'F (Ref. 35) and the margin in this section is the highest calculated and is not greater than 32*F (Ref. 24).
The subcooling margins in the subsequent sections of the horizontal run are lower in magnitude as the distance from the drywell cooler increases (refer to Attachment 2, figure 5).
Slug Acceleration As stated previously, the pressures in the cooler will cause-voiding in the piping system.
The steam will quickly reach outside containment.
This is represented graphically in Attachment 2, figure 6 where the distance the steam would travel is plotted against time.
Figure 6 also shows the steam pressures during the transient.
Because the boiling in the cooling coils mixes with the fluid in the tubes and adjacent piping, no actual slug exists.
As long as the RBCLC pumps are not re-started, or the RBCLC AOVs are closed prior to reatarting the pumps, there can be no slug acceleration.
Void Collapse / Impact As the expanding steam accelerates the water in the cooling coil headers and adjacent piping, the hot Page 8 of 40 l
interface that borders the steam void is maintained.
This is because the cooling coils are at a low point relative to the adjacent piping and the saturation temperature decreases as the hot water in the adjacent piping moves upwards.
The maximum impact overpressure occurs given a maximum pressure difference and minimum slug length.
Although there may be small slugs of water around the steam voids that are created, the resulting acceleration is small.
2.
Water Cannon
[ Severity - minor)
This event class of waterhammers has occurred in HPCI systems of BWRs, where the turbine exhaust lines enter the suppression pool.
The water cannon event begins as steam exhausts into a pool of subcooled water.
A discharge valve is closed such that a segment of high-pressure steam is l
trapped above the surface, the steam condenses rapidly and the liquid is quickly drawn into the discharge line where the closed valve stops it.
These conditions are not present for JAFs drywell coolers.
In addition, these conditions are not present in the HPCI and RCIC systems due to the use of vacuum breaker lines in the steam discharge piping.
3.
Trapped Void Collapse
[ Severity - minor to moderate]
This is the most common event class of waterhammers.
It has l
occurred in BWR condenser, Core Spray, process steam RHR and l
Se:.vice Water systems.
Typical component damage includes pipe support and snubber failure, rupture of instrument lines, small pipe deformations and valve or small component damage.
l The event begins with trapping of a steam void, due to a variety of means.
Void collapse is initiated by repressurization, which might occur due to opening of a valve, restarting a pump or other mechanisms.
As the void vanishes, the slug or column of water is suddenly decelerated, resulting in waterhammer.
For this waterhammer the water column velocities would be driven by the RBCLC pumps and could become quite high.
In fact, the column velocities can exceed the normal flow velocities since the flow resistance for a water column is less than the flow resistance in the entire loop.
The existence of parallel channels can further exacerbate the situation by allowing water columns to be accelerated from two sides, yielding high relative impact velocities and associated large pressure spikes.
Two scenarios exist where this type of.eterhammer could Page 9 of 40 l
l 1
f A
occur.
The first scenario is where a LOCA occurs with a LOOP and the operators elect to use the Emergency Service Water (ESW) system to provide drywell cooling.
The second scenario is similar to the first, but instead of using ESW, power is restored and the RBCLC system is available.
The scenario where a LOOP occurs without a LOCA was reviewed, but discounted.
This type of event occurred in September of 1996 and drywell temperatures increased very slowly.
Review of the shift manager log (Ref. 34) on 9/16/96 showed operators restored drywel? cooling using ESW approximately 26 minutes into the event.
Review of the l
Post-Transient Event report (PTE-96-002 - Ref. 33) showed that drywell pressure increased less than 0.5 psig during l
that time.
The pressure peaked roughly 2 minutes before drywell cooling was re-initiated.
Scenario 1 - LOCA/ LOOP & ESW used for cooling:
For the first scenario, an interface does exist from the RBCLC to the safety related ESW system (FM-46B).
However, at JAF, the interconnecting piping circuits from ESW to RBCLC are isolated by normally closed valves ( 4 6ESW-10A&B, 14A&B, 17A-D,and 15MOV-102&l03) which require manual operator action.
If the RBCLC system is lost for any reason, the ESW system will automatically inject into.the RBCLC system with the exception of the drywell.
The valves listed above require manual action to feed ESW to the drywell portion of the RBCLC system.
Manual operator action to feed ESW to the drywell portion of the RBCLC system is controlled by plant procedure AOP-11 (Ref. 30).
Within this procedure several cautions and instructions are given to the operator, which are directly related to the " bypass flow path" concern. The first CAUTION states: " Cross-tying ESW loops to RBCLC could divert ESW from safety related loads".
The operator is subsequently instructed to monitor crescent area temperatures to ensure adequate cooling water is being supplied to the safety related coolers.
The next CAUTION specifically states:
" Supplying ESW to the Drywell Coolers could divert ESW from safety related loads".
Here again the operator is instructed to monitor crescent area temperatures.
- Also, the operator is
(
instructed that if the Drywell floor drain leak rate rises or cannot be determined he should isolate ESW from the RBCLC system.
This is accomplished by remote / manual operation of RBCLC CIV's (15AOV-130A& B, j
131A&B, 132A&B and 133A&B) from the control room.
l It has been recognized, however, that a water hammer may be initiated by operator action to supply ESW to the RBCLC during postulated accident conditions.
Page 10 of 40 l
l m________...______
l AOP-11 was previously revised to add a statement concerning the generation of a water hammer in the RBCLC system as a NRC commitment (JPN-97-003-01),
which was tracked under ACTS # 24617.
The CAUTION states: " Supplying ESW to drywell loads during a LOCA could cause failure of RBCLC piping due to waterhammer, and is prohibited."
Scenario 2 - LOCA/ LOOP & RBCLC used for cooling:
For this scenario, the same prohibition exists in AOP-11 as for the previous scenario, but a question was raised regarding whether the RBCLC pumps would automatically restart when the power is restored l
following a LOOP.
A review of AOP-57 (Ref. 30) shows l
that for a residual transfer, the RBCLC pumps (15P-2A, B & C) are placed in a
" Pull-to-Lock" (PTL) condition.
AOP-11 is then used for recovery and l
contains the LOCA prohibition.
l l
LOOP under SBO Conditions Although this scenario is beyond JAFs design basis and does not specifically require consideration in response to GL-96-06, this was also reviewed.
AOP-49 (Ref. 31) is similar to AOP-57 and requires the RBCLC pumps to be placed in a PTL condition.
AOP-11 is again used for recovery from this event.
Based on the actions described for the above scenarios, this type of waterhammer will not occur at JAF.
Since the pumps are not in service, there is no appreciable driving head to cause this type of waterhammer to take place until the system is intended to be returned to service.
At that time, additional considerations need to be taken by operations with engineerin taff input to prevent a waterhammer from occurring.
As a minimum, EOPs and/or EOP implementing procedures should contain guidance that the following items are considered, prior to returning containment coolers to service:
- Containment temperature System pressure System inventory 1
These three minimum items define the potential for waterhammer and two-phase flow and are basic to all plants.
Discussion of each item follows:
Primary containment temperature - This temperature l
definer the saturation temperature and pressure for boiling within the coil tube bundles.
The lower the containment temperature the less the likelihood of water boiling within the tubes (and subsequent potential coil tube voiding).
System pressure - The cooling water (RBCLC or ESW) system Page 11 of 40 l
pressure determines if potentia] boiling can occur given the containment temperature.
The restart criterion needs to include the effects of cooler elevation and its effect on potential boiling in the coils.
System inventory - The inventory of the system needs to be monitored following drywell cooler restart to assure that adequate water inventory is available.
A loss of adequate inventory could be due to breaches in system integrity.
Additional items that may also require consideration at the time the system is returned to service include, but are not i
limited to:
system components (e.g.,
EQ limits, design temperatures, etc.)
instrumentation available RBCLC pump,NPSH
- heat removal capability of RBCLC heat exchangers potential flashing of high temperature water in downstream sections of the system the rate and method by which water from the RBCLC system can be readmitted into the piping to avoid significant waterhammer loads 4.
Saturated Water Slug
[ Severity - minor to moderate']
This event class of waterhammers is also fairly common.
It has occurred in BWR HPCI and RCIC systems and in PWR Feedwater systems.
A slug of water is formed either by condensation at a low point in a piping system or by inadvertent injection of liquid into a steam filled line.
The waterhammer is triggered when opening of a valve, starting of a pump, etc., suddenly accelerates the slug of water.
These conditions are not expected to be present in the scenarios applicable to JAF.
The reasons are as follows:
The piping to the drywell coolers in the drywell is uninsulated.
The drywell coolers, based on their greatly superior heat transfer capability, will be where steam bubbles are first formed.
Based on this, there is no condensate available at the low point of the system that will be pushed out by the steam that is generated in the coolers.
The steam initially " pockets" in the coils and then expands to the adjacent piping.
Actually, the steam would be expected to initially develop in the upper coils of the coolers (lower saturation temperature due to lower head pressure), boil.out the coil into the adjacent piping and then mix with the water in the vertical headers.
The horizontal piping will heat up due to conduction and convection heat transfer on the outside of l
l Page 12 of 40 l
the piping and from the convection heat transfer from the rising hot water in the coil headers.
This continues with the lower coils as the water in the lower coils also boils.
As more. water turns to steara and the steam expands, it pushes any water outward and upwards towards the discharge of the drywell coolers (because there are check valves preventing reverse flow in the inlet piping).
The steam will eventually expand to fill more piping.
The type of waterhammer described is.not possible under these conditions because there is no slug of water that can be picked up and transported.
5.
Thermal Inversion
[ Severity - moderate]
This event class of waterhammers has been primarily reported in the feedwater systems of fossil power plants, although one event occurred in a nuclear plant in Great Britain.
The event begins with an elevated reservoir of relatively cold water and a bottom draining outlet pipe having hot water.
The concern is when the normal outlet flow in the pipe is reversed under transient conditions.
As the hot liquid-rises, it's saturated pressure drops until it becomes superheated.
At this point, the liquid flashes 1
and steam begins to form.
The presence of steam voids above l
the hot fluid column further. reduces the pressure, causing j
more liquid to flash and quickly voiding the entire line above the hot water.
Cold water then drains into the voided line driven by gravity and reduced pressure in the void due to condensation.
When the cold and hot columns strike, a
waterhammer pressure pulse is generated due to the sudden deceleration of the fluid columns.
f, This event is not postulated to occur ;or the drywell coolers at JAF.
As discussed previously, the steam generated in the drywell coolers will eventually void the-coolers.
The uninsulated cooler inlet and discharge piping I
lines also heats up, however, due to steam condensation on the cooler piping and heat transfer from steam generated in the coils moving out from the cooling coils.
Because of this, water in both the coolers and the adjacent piping reaches saturation temperature fairly rapidly.
Thus there-is no slug of cold water to drain into the void created by bt ling in the cooler coils.
6.
Conventional Waterhammer
[ Severity - not shown in table]
This event c?rss of waterhammers is generally caused by abrupt val.
ures, unsteady oscillations of components, and pump stars d stops and other dynamic interactions that do not involte condensation as the event trigger.
The RBCLC system is a closed loop system equipped with a " head tank".
There are also controls for placing equipment in or out of service that prevent this type of event.
When Page 13 of 40 l
placing a new heat exchanger in service for example, OP-40 requires operators to ensure the heat exchanger is filled and vented prior to opening the outlet flow control valve.
Because of the system design and procedural controls which control placing equipment in service or removing it from service,.the potential'for this type of waterhammer does not exist.
The next class of waterhammer is not discussec in the referenced NUREG, but is discussed in the EPRI report.
7.
Column Rejoining Waterhammer
[ Severity - not shown in table]
This occurs when a void is created in the piping either due to draining of the fluid or steam or some type of non-condensable gas creates a pocket in the piping system.
Fluid draining is prevented through the use of a " head tank"
-and proper routing of piping lines.
The potential does exist for a pocket of gas to be created when the LOCA environment' heats the water to boiling, as discussed in some of the scenarios above, but this has been addressed in these scenarios.
The conventional waterhammer and trapped void collapse scenarios bound the column rejoining waterhammer considered in this class.
Modeling Considerations (Reference.24)
The waterhammer evaluation is highly dependent on the results of the-heat transfer model.
The heat transfer model used in the evaluation applied the Environmental Qualification (EQ) temperature profile curves to conservatively bound both the DBA and SBLOCA conditions.. Sensitivity evaluations were performed to assure conservative. inputs such as:
steam / air fractions, heat transfer coefficients, pump and fan coastdowns, segment lengths and time steps used.
The heat transfer model has an integral hydraulic interface to ensure appropriate water velocities are modeled during the event.
Heat transfer across the drywell coolers and piping wall was modeled.
Steam and water mixing in each segment was modeled to allow evaluation of segment temperatures, pressures, flows and
.subcooling at any time.
Attachment 2,
figure 7
shows the
(
. temperatures in each segment during the event.
In any two-phase flow heat transfer analysir there is a level of uncertainty associated with correlating theoretical and empirical bases to real world configurations.
Appropriate levels.of t
conservatism were included in the evaluation to bound these
-differences.
As' an~ additional level of assurance, if condensation-induced waterhammer was postulated to occur at subcooling margins of less than 36 F,.then a condensation induced waterhammer pressure pulse of 51' psi is calculated at the worst case subcooling condition.
The magnitude of this pressure pulse is judged to be of minimal Page 14 of 40 l
1 o
bignificanceand19 not unlike typical pressure pulses associated l
with such routine occurrences as pump starts or valve closure.
i Condensation induced-waterhammer is not possible inside the drywell cooling coils because there is insufficient subcooling I
margin between the steam and water in the tubes.
I l
Regarding the potential for 2 phase
- flow, the lowest RBCLC drywell cooling return piping pressure inside containment during pump operation would be 32 psia.
This is assuming no LOOP concurrent with a
LOCA.
This corresponds to a
saturation temperature of 254'F.
The LOCA/ LOOP event was already considered l
under event 3, Trapped Void Collapse, where voiding is expected to occur.
Heat transfer calculations performed for normal flows at accident conditions indicate that the temperature rise across the drywell coolers would not be sufficient to bring the water to saturation.
Therefore, two phase flow conditions are not expected inside containment during a LOCA with a normal RBCLC operating configuration.
i NRC Information Notice 96-60 l
Additionally, NRC Information Notice 96-60 " Potential Common Mode Post-Accident Failure of RHR Heat Exchangers" dated November 14,1996 has been linked to Generic Letter 96-06 by the NRC. This Information Notice has been evaluated by Tech Services. It was shown that JAF's use of an RHR Keepfull System precludes the l
concerns of this NRC Information Notice.
Details of this l
evaluation are contained in the OE files (ref. DER # 96-1560).
l Based on the above it is concluded that the water hammer / two phase flow concerns of the NRC generic letter 96-06 are not applicable to JAF.
l l
l i
l l
l l
l Page 15 of 40 l
l
TEERNAL PRESSURIZATION ITEM 2 GENERAL Generic Letter 96-06 states " Thermally induced overpressurization of isolated water filled piping sections in containment could jeopardize the ability of accident mitigating systems to perform their safety functions and could also lead to a
breach of j
containment integrity via bypass leakage".
The industry events presented in the generic letter illustrate that the concern not only deals with piping system pressure boundary integrity but also the ability of the isolation valves to allow the systems to perform their safety function. In order to analyze this issue the following evaluation process was used:
a thorough review of all Drywell and Suppression Pool penetrations was made to identify those which involved liquid systems, valve arrangements for the above systems were reviewed to determine if isolated nter filled sections exist and if thermal pressurization was possible, a heat transfer model was developed to determine the effect of the post accident ambient area temperatures I
on the isolated water temperature for selected penetrations from which trapped fluid pressure was calculated, valve analysis was performed on the susceptible penetration isolation valves to determine their maximum pressure retaining capability, the limiting internal pressure of the isolated pipe section was then determined, containment integrity and safety system function were then evaluated for the DBA thermal pressurization i
condition.
SCREENING RESULTS All containment penetrations (584 total) were reviewed, of which 314 contained isolated water sections (Control Rod Drive system accounts for 274 of these penetrations). Attachment 1 provides details of the penetrations containing isolated water sections.
Based on the screening process, only 14 penetrations had isolated l water filled sections which were susceptible to thermal pressurization, but subsequent review of operator actions associated with AOP-11 identified another 9 penetrations which could be susceptible:
Page 16 of 40 l
Two. (2) penetration (X-14 and X-41) were eliminated from further thermal pressurization and containment integrity evaluation since the water temperature during normal operating conditions would be the same or higher than the water temperature under DBA conditions.
One (1) penetration (X-12) was eliminated from thermal [
pressurization and containment integrity evaluation due to installed valve design features (e.g. bonnet bypass) which limited the pipe line pressurization to below design pressure.
Nine (9) penetrations (X-23, X-24, X-62, X-63, X-64, X-65, X-66, X-67 & X-68) are associated with RBCLC lines penetrating containment that supply the drywell coolere or Reactor. Water Recirculation (RWR) pumps.
These lines contain normally open AOVs that do not receive an auto-isolation signal.
Closure of these valves following an accident requires manual operator action.
Thermal expansion can occur when the initial fluid temperature is lower than the temperature of the primary containment following an accident and the valves are subsequently isolated per AOP-11.
Thermal expansion is evaluated in the discussion section that follows.
The remaining eleven (11) penetrations (X-8, X-18, X-19, X-39A, X-39B, X-210A, X-2108, X-211A, X-211B, X-
- 224, and X-226) were analyzed at the limiting calculated pressure for each penetration.
l Page 17 of 40 l
.1
8 SYSTEM SAFETY FUNCTION REVIEW FENERAL The generic letter presented an industry experience for Beaver Valley Units 1 and 2 in which a motor operated valve associated with an isolated section of thermally pressurized piping would not opan during a surveillance test. Since isolated piping sections, l
which penetrate containment, will be expased to thermal pressurization the potential for systems to fail to perform their safety functions needed to be evaluated.
In order to disposition this issue the valves associated with the penetrations identified above were reviewed for post accident operating requirements.
The results of this evaluation are presented below.
DISCUSSION Penetrations X-8, X-18, X-19 and X-224 do not have safety functions. The associated CIV's are either normally closed or receive a signal to close for DBA conditions and remain closed for the duration of the event.
Penetrations X-39 A&B, X-210 A&B and X-211 A&B employ inboard globe valves with isolated fluid under the seats An increase in isolated fluid pressure due to thermal conditio..s would assist valve opening. Therefore valve operability and consequently system safety function would not be jeopardized.
Penetrations X-23, X-24, X-62, X-63, X-64, X-65, X-66, X-67 & X-68 employ normally open air operated globe valves.
There are two factors that prevent thermal pressurization that could cause damage to these penetrations.
The first is the pressure relieving capability of the isolation valves and the second is the condition of the fluid in the lines at the time the valves would be isolated.
l Valve Pressure Relief:
Because the RBCLC piping enters at one or more penetrations and has a
corresponding outlet l
penetration, at least one valve per penetration pair has the potentially isolated fluid under its seat.
An increase in isolated fluid pressure would assist valve
-opening once the difference between the operator diaphragm closing force and spring opening force is overcome.
A review of calculations (Ref. 28) performed by the actuator manufacturer and a discussion with the preparer of the calculation shows the pressures required to cause leakage can be determined by dividing the seating load by the unbalanced area between the valve cage and seat ring.
A quick review of the reference 28 calculation shows that the maximum pressure required to cause seat leakage is between 234 and 250 psig for all RBCLC isolation valves.
This is well below the hydrostatic test pressure for these l
valves and is nearly identical to the initial leak test pressure for the system of 225 psig.
Therefore, valve Page 18 of 40 l
operability and the safety function of the system pressure boundary would not be jeopardized.
Fluid Condition When the Valves are Isolated:
Because the valves do not receive an auto-isolation
- signal, there is a finite period of time that will elapse before plant operators manually isolate the valves.
Operating procedures only direct these valves to be isolated if there are symptoms that indicate a potential breach in the RBCLC piping integrity.
Because this requires time to diagnose the condition and ~ take action to close the valves and because JAFs licensing basis assumes 10 minutes elapse before operator action can be assumed, a 10-minute duration was chosen.
A review of the containment accident profiles for various LOCAs shows that drywell temperature, which exceeds saturation temperature for RBCLC, has peaked within 10 minutes.
In
- addition, the reference 24 l
Altran report shows that voiding would occur in the drywell cooling coils and the majority of the fluid heatup will occur in other piping at this point ' in time.
Because of this, there is no possibility of l
creating the conditions that can cause thermal pressurization of the RBCLC penetrations and these penetrations were not considered further.
The valves associated with penetration X-226 (23MOV-57 58) provide a transfer function for the HPCI pump suction source from the Condensate Storage Tank (CST) to the Torus.
HPCI pump suction L
is normally lined up to the CST as the preferential source.
Potential thermal pressurization of this' containment penetration configuration is due to elevated Torus temperature.
A preliminary review of the plant transient and accident analyses indicates transfer function will not be used except for either initiating events which would render the CST's unavailable or non mechanistic failure of non safety related sections of the system.
This conclusion was based on a) the HPCI system required operating time and b) the rate of depletion of inventory in the CST's. Further evaluation was made to determine if thermal pressurization could adversely affect the availability of the transfer function.
i Existing Design Basis and EQ documents were reviewed which established that the maximum expected operating time of the HPCI system was eight (8) hours.
The time to develop thermal pressurization was evaluated based on the physical configuration of the penetration and the ambient conditions during a small break LOCA. The penetration is not subjected to steam condensing heat transfer, the piping in the Torus Room is insulated, and the Torus temperature during the event is below its peak. These facts coupled with the analytic results for the large break LOCA case (Ref. 6) led to the conclusion that thermal pressurization would take greater than eight hours to develop. Based on the above
- input, it was concluded that no accident sequences have been identified which would require opening of these valves coincident with elevated Torus temperature.
Break size, rate of Reactor depressurization, quantity of outflow l
Page 19 of 40 l
.from the CST, and rate of Torus temperature rise are all factors that affect this evaluation.
Since HPCI has a wide range of operating scenarios, all of these factors can vary significantly.
Detailed data is only available for certain bounding conditions.
Qualitative assessment has concluded that the HPCI system safety function will not be jeopardized. There is, however, an area of uncertainty.
Because of this uncertainty, NYPA has performed a quantitative assessment of the potential for pressure locking.
Due to the design features (solid wedge gate valves, SS seats) of the valves in this penetration, the valves are expected to have sufficient leakage to prevent this phenomenon.
A calculation (Ref. 26) determined that based on the maximum heatup rate of the water inside the piping between 23MOV-57 and 23MOV-58, the leakage rate that equates to the rate of volumetric increase due to thermal expansion is roughly 200 ml/hr.
This valve leakage rate is roughly 120% of the acceptable leakage rate for a new valve (single valve in this penetration).
Since there are two valves that form the pressure boundary for this section of piping, this represents roughly 60% of the acceptable leakage rate for this penetration with new valves at their maximum allowable leakage.
There are no Appendix J 1eakage requirements for these valves because they are water sealed.
The NRC, in response to questions about using valve leakage, has imposed the following constraints,(Ref. 27, Attachment 1, 06) :
=>
Leakage is quantifiable
=>
Leakage is predictable
=>
Leakage is known Leakage is evaluated in terms of impact on other plant
=>
equipment performance obviously, if the required leakage is less than what was allowed for in the original design and installation, the impact on other plant equipment is insignificant and requires no further evaluation.
Leakage rates will require testing, perhaps on a periodic basis.
A temporary operating procedure has been prepared to collect the necessary information for further evaluation.
This testing will establish whether the leakage can be quantified, predicted and known.
This action will be tracked by ACTS #98-34168 as a commitment to complete the testing and evaluation concluding that there is no potential for pressure locking prior to startup from R0-13.
Per the RCIC DBD and MCM-6A, the RCIC system has no defined safety functions other than isolation valve closure.
The valves associated with penetration X-224 are 13MOV-41 (inboard) and 13MOV-39 (outboard).
These valves are normally closed.
Although penetration X-224 does not have a safety related system i
function, it is also susceptible to thermal pressurization during operating transients due to potential elevation of Torus temperature. The valves associated with this penetration provide Page 20 of 40 l
l l
the same function as penetration X-226, that is, transfer of RCIC pump suction source from the CST to the Torus.
13MOV-39 and 41 would be opened on a low CST level and subsequently closed using remote manual means (i.e.
operator action).
The Reference 2
-Safety Evaluation evaluated. valve.13MOV-39 for penetration X-224.
It was determined that this valve does not perform a containment isolation function and will be removed from AP-01.04. Because the flow rate for RCIC is small (approximately 400 GPM),
the likelihood that ' RCIC will nead to transfer to the suppression pool. is highly unlikely.
This is compounded by the fact that RCIC will be more likely to fail on high suppression pool temperatures than if it were to maintain suction on the CSTs.
JAFs Individual Plant Examination (IPE) was also reviewed with respect to the various accident sequences that involve RCIC.
In all cases, the RCIC system is assumed to fail either due to random failures or a loss of steam pressure from the RPV.
In no case is the suction from the. Suppression pool credited because there is no automatic swapover feature for RCIC.
Due to this and the fact that there is no safety function to open these valves, the RCIC valves should not be modified.
l l
l l
Page 21 of 40 l
i.
CONTAINMENT INTEGRITY REVIEW GENERAL During the initial stages of this evaluation it was recognized that penetrations X-8, X-12, X-18, X-39A, X-39B, X-210A, X-210B, X-211A, and X-211B would have their pressure conditions limited by valve design features. Such features included: a) double disk gate valve designs with either bonnet bypass or a drilled disk, and b) globe valve designs with isolated fluid under the seat. For these penetrations, the Authority performed calculations (Ref. 5& 6) to determine the limiting isolated fluid pressure that the penetration would experience due to thermal pressurization.
SWEC performed detailed analyses for penetrations X-19, X-224, and X-226 (Ref.
7, 8,
and 9) using a zero valve leakage assumption since the initial screening did not reveal a valve design feature which would limit the isolated fluid pressure.
The analyses included:
a) a heat transfer model to cvaluate the effects of DBA condition area temperatures on the isolated fluid temperature, and b) a pressure calculation to determine the resultant pressure of the isolated fluid due to thermal pressurization.
SWEC then performed stress evaluations (Ref. 10 through 17) to determine the acceptability of the stresses in the penetration section of piping and its associated components due to the thermal pressurization.
The analyses performed by SWEC considered the containment isolation valve (CIV)
- bodies, however it did not evaluate the valve internals.
Altran was contracted to evaluate the integrity of the internals of the CIV's, due to their extensive involvement in the GL 89-10 program.
The results of their evaluation (Ref.
4) provided limiting pressure data for penetrations X-19, X-224, and X-226.
The Altran analysis showed that these three penetrations would develop a leak path at the CIV's due to thermal pressurization.
The stress evaluation for these three penetrations was subsequently re-evaluated by SWEC based on the Altran pressure results.
ACCEPTANCE CRITERIA As part of the GL 96-06 evaluation, a review of the JAF's design code of record, ANSI B31.1 Power Piping Code 1967 Edition, and its Licensing basis was performed.
Neither of these two documents l
provide acceptance criteria for evaluation of fluid expansion effects due to accident conditions.
Therefore, plant specific j
acceptance criteria were developed for this evaluation.
Maximum allowable internal pressures are calculated in accordance with the ANSI B31.1 Code equations for minimum wall thickness and general pipe stress (which includes a longitudinal pressure term) using criteria allowed by ASME Section III Appendix F and IP-PS-Page 22 of 40 l
04, Pipe Support Analysis Procedure.
Maximum allowable internal l pressures for integrally welded pipe attachment (IWA) pipe supports are calculated using the appropriate load combinations defined in Ref. 21 (Table 4.8.1-1).
These " maximum allowable internal pressures" for each penetration are then compared to the maximum attainable pressure caused by thermal pressurization between the isolation valves.
The integrity of the piping is assured when maximum allowable internal pressure values envelop l the thermal pressurization levels.
The maximum allowable pressures are calculated as shown below.
Minimum Wall: (For Evaluation of Piping) 2 Sh ( t m - A)
P=2
_ D o - 2 y ( t m - A).
I Normal / Upset Primary Stress: (For Evaluation of Piping & IWA Pipe Supports)
So..eweignt + Stongitudin.1 Pressur, + SRSS(Soest, Soce.stor.1) s 2.4Sh
' 9,. d: s 2
P = (2.4 xSh - Stotu urscreiuuay) x
+ Potuon 2
d u
I Faulted Primary Stress:
(For Evaluation of Piping &
IWA Pipe Supports)
So..eweignt + S engitudin.1 Pressur. + SRSS ( Soner, Soce.. ion.1) s 2.4Sh t
P = (2.4 xSh - Storu nutroa riumav) x ' D, - d' '
+ P 2
2 otsias d
Where:
P - maximum allowed internal pipe pressure (psi)
Sh - allowable pipe stress at temperature (psi) l tm - minimum wall thickness, including manufacturers allowed tolerance (inches)
A - additional thickness to compensate for material removed in threading, etc. of pipe and to provide for mechanical strength (inches)
Do - outside diameter of pipe (inches)
Page 23 of 40 l
d - incide diameter of pipe (inches) y a
coefficient to account for pipe material and temperature SRSS - Square Root of the Sum of the Squares So..ow.igne Pipe stress. due to the deadweight (the existing value will not change due to thermal overpressurization).
SLongitudin.1 pressur.
Pipe stress due to internal pressure computed in accordance with the BOP Piping Stress and Supports Design Criteria (Ref. 21).
Soser and Soser - Pipe stress due to operating basis and design basis earthquakes respectively (the existing value will not change due to thermal overpressurization).
Soce.. ton.1 - Pipe stress due to hydrodynamic events such as SRV discharge, chugging, etc are short duration events.
Loads from these events will dissipate long before the internal pressure can increase significantly.
Therefore, they need not be included in the plant operability pipe stress checks for thermal pressurization concerns.
Potsrow - Existing design pressure of ' pipe l'
i e
Page 24 of 40 l
4
f-RF. SUI.TS The: following (11) penetrations determined to be susceptible to thermal pressurization had stress evaluations performed (Ref. 3).
These are summarized below.
The
> ;nmaries only show the pressures associated with the limitin' scress component.
Penetration X-8 The following components are subjected to thermal overpressurization and are addressed in Reference 10:
Pipe Line No.: 3"-SHP-902-3A, 3"-SHP-902-6 l
l Pipe Supports: None Penetration:
X-8 System:
Main Steam Line Drain An evaluation of the piping and the penetration listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 3,546 psi.
Calculation No.
JAF-CALC-MULTI-02591 (Ref.
5) calculates, for containment isolation valve 29-MOV-74, a differential pressure across the valve seat, which will lift the valve, allowing the l internal pressure to be relieved.
The table below shows the differential pressure to lift the valve, the design pressure of the outboard pipe (relative to the isolated section) and total l
pressure.
The design pressure is added to the differential 1
- pressure to bound a spectrum of DBA analysis cases.
Differential Pipe Outboard Design Total Valve No.
Pressure of Valve, Pressure Pressure (psi)
Relative to (psi)
(psi)
Isolated Section 29MOV-74 2091 3"-SHP-902-3?.
1146 3237 The maximum internal pressure due to thermal overpressurization (3,237 psi) is within the maximum allowable internal pressure (3,546 psi).
Therefore, the acceptance criterion has been met for l the affected piping and piping components associated with Drywell Penetration X-8.
t Page 25 of 40
[
enetraticn X-18 l
This section is revised to add an additional scenario.
The original evaluation (Scenario 1) assumed that check valves 20RDW-80A and 80B will not. hold thermal pressure. Scenario 2 is added which assumes that these check valves do hold (no leakage) thermal pressure.
The following components are subjected to thermal overpressurization and are addressed in Reference 20:
Pipe Line No.: 3"-WL-151-2 and %" Vent Pipe Supports: None Penetration:
X-18 and S-263 System:
Drywell Floor Drain Sump Discharge Note: Line Nos. 3"-WL-151-1A and 1B (between check valves 20RDW-80A E BOB and l valve 20MOV-82) may also be subjected to thermal pressurization.
Since they are not required for containment integrity, they have not been analyzed.
An evaluation of the piping and the penetrations listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 2,188 psi.
'I,o scenarios 'were evaluated as follows:
Scenario 1:
Scenario 1 assumed that check valves 20RDW-80A & 80B will not hold thermal pressurization. Therefore, the pipes inboard (containment side) of isolation valve 20MOV-82 can provide a relief path when the pressure build up inside the isolated pipe section (between isolation valves 20MOV-82 and 20AOV-83) causes valve 20MOV-82 to leak.
Calculation Number JAF-CALC-MULTI-02591 (Ref. 5) calculates, for containment isolation valve 20MOV-82, a differential pressure that will cause the valve to leak, allowing the internal pressure to be relieved.
The table below shows the differential pressure, the design pressure of the outboard (relative to the isolated section) pipe and total pressure.
Differential Pipe Outboard Design Total Pressure of Valve, Pressure Pressure Valve No.
(psi)
Relative to (psi)
(psi)
Isolated l
Section 1
20MOV-82 264 3"-WL-151-1A 150 414 l
The maximum internal pressure in this scenario is 414 psi.
i r
Page 26 of 40 l
1
{.
1
(
L
Scenario 2 Scenario 2 assumed that check valves 20RDW-80A & 80B will hold the thermal pressurization.
Therefore, the pipes inboard of 'the l
' isolation valve 20MOV-82, line Nos.
3"-WL-151-1A & 1B between check valves 20RDW-80A & 80B and isolation valve 20MOV-82, will also be subjected to thermal pressurization.
The pipes inboard of valve 20MOV-82 (lines 3"-WL-151-1A & 1B) are l completely exposed to the drywell temperature (whereas only a portion of the isolated section between 20MOV-82 and 20AOV-83 is exposed).
Therefore, these piping sections are subjected to thermal pressurization and the internal pressure between check valves 20RDW-80A & 80b and 20MOV-82 will be greater than the pressure between 20MOV-82 and 20AOV-83. Since the pressure inboard of valve 20MOV-82 is greater than the pressure outboard, the valve will seat tighter. As a result, the internal pressure in the isolated section of pipe at the penetration will increase until it causes valve 20AOV-83 to
- leak, limiting the thermal pressurization.
Altran calculation No. 96254-TR-01 (Ref. 4) determined, for valve 20AOV-95, a differential pressure which will cause the valve to leak. Valve 20AOV-83 is identical to valve 20AOV-95, therefore, they will have the same characteristics. The table below shows the differential
- pressure, the design pressure of the outboard (relative to the isolated section) pipe and total pressure.
Valve No.
Differential Pipe Outboard of Design Total Pressure Valve, Relative to Pressure Pressure (psi)
Isolated Section (psi)
(psi) 20MOV-83 1467 3"-WL-151-2 150 1617 In scenario 2, the maximum internal pressure is 1,617 psi.
The maximum internal pressure, considering both scenarios 1 and 2, due to thermal pressurization (1,617 psi) is within the maximum allowable internal pressure (2,188 psi). Therefore, the acceptance criterion has been met for the affected piping and piping l components associated with Drywell Penetration X-18.
The leak path for 20AOV-83 is considered to be a non-resealing leak path due to the seat materials used in the valve.
Regardless, if 20MOV-82 is sufficiently leak tight to allow the pressure to build to the point where 20AOV-95 leaks, the overall penetration leakage is not a concern.
1 Page 27 of 40 l
l
enetratien X-19 l
The following components are subjected to thermal overpressurization and are addressed in Reference 11:
Pipe Line.No.: 3"-WH-151-7 and %" Vent Pipe Supports: None Penetration:
Y-19 and S-258 System:
Drywell Equipment Drain Sump Discharge An evaluation of the piping and the penetrations listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 2,188 psi.
Altran calculation No.
96254-TR-01 (Ref.
4)
- states, for containment isolation valve-20AOV-95 (the outboard ball valve), a differential pressure which will cause the valve to leak, allowing the internal pressure to be relieved.
-The table below shows the differential
- pressure, the design-pressure of the outboard l
(relative to the isolated section) pipe and total pressure.
Valve Differential Pipe Outboard Design Total No.
Pressure of Valve, Pressure Pressure (psi)
Relative to (pui)
(psi) i Isola'ted Section' j
20AOV-95 1467 3"-WH-151-7 150 1617 The maximum internal pressure due to thermal overpressurization (1617 psi) is within the maximum allowable internal pressure (2,188 psi).
Therefore, the acceptance criterion has been met for l the affected piping and piping components associated with Drywell i
Penetration X-19.
'The leak path for 20AOV-95 is considered to be a non-resealing leak path due to the seat materials used in the valve.
Regardless, if 20MOV-94 is sufficiently leak tight to allow the pressure to build to the point where 20AOV-95 leaks, the overall penetration leakage is not a concern.
l i
I i
Page 28 of 40 l
]
Penetration X-39A
~ he following components are subjected to thermal T
overpressurization and are addressed in Ref. 18:
Pipe Line No.: 10"-W20-302-12A Pipe Supports: H10-397, PFSK-1928, and PFSK-1917 Branch:
2"-AS-302-55A, 1%"-AS-302-55A, and 1"-AS-302-55A Penetrations:
None System:
l An evaluation of the piping and the pipe supports listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is l
l'684 psi.
Calculation No.
JAF-CALC-RHR-02589 (Ref.
6) calculates, for containment isolation valve 10MOV-31A, a differential pressure across the valve seat, which will lift the valves, allowing the l internal pressure to be relieved.
The table below shows the differential pressure to lift the valve, the design pressure of l
the outboard (relative to the isolated section) pipe and total pressure.
Valve No.
Differential Pipe Outboard of Design Total l
Pressure Valve, Relative Pressure Pressure l
(psi) to Isolated (psi)
(psi)
Section 10MOV-31A 703 10"-W20-302-12A 325 1028 The maximum internal pressure due to thermal overpressurization
[
(1028 psi) -is within the maximum allowable internal pressure l
(1,684 psi).
Therefore, the acceptance criterion has been met for l l
the affected piping and piping components associated with Drywell Penetration X-39A.
I i
l Page 29 of 40 l
r P:netre, tion X-393 The following components are subjected to thermal
.overpressurization and are addressed in Ref. 19:
Pipe Line No.: 10"-W20-302-12B Pipe Supports: H10-521 and PFSK-2393 Branch:
1%"-AS-302-55B, and 2"-AS-302-55B Penetrations:
None l
System:
An evaluation of the piping and the pipe supports listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 1,684 psi.
Calculation No.
JAF-CALC-RHR-02589 (Ref.
6) calculates, for containment isolation valve 10MOV-31B, a differential pressure across the valve. seat, which will lift the valves, allowing thel internal pressure to be relieved.
The table below shows the differential pressure to lift the valve, the design pressure of the outboard (relative to the isolated section) pipe and total j
pressure.
l Valve No.
Differential Pipe Outboard of Design Total Pressure Valve, Relative Pressure Pressure (psi) to Isolated (psi)
(psi) l Section.
l 10MOV-31B 703 10"-W20-302-12B 325 1028 l
The maximum internal pressure due to thermal overpressurization (1,028 psi) is within the maximum allowable internal pressure (1684 psi).
Therefore, the acceptance criterion has been met forl the affected piping and piping components associated with Drywell Penetration X-39B.
.i l
i Page 30 of 40 l
Penetration X-210A l
-The following components are.
subjected to thermal overpressurization and are addressed in Reference 12:
hpe Line. No. : 16"-W20-302-15A Pipe Supports: PFSK-1940, PFSK-1944 & PFSK-1984
' Penetration:
None-System:
'RHR to Suppression Pool An evaluation of the piping and the pipe supports listed above determined that the maximum-internal pressure for which the acceptance criteria-defined.on page 7'of this report can be met is 1,565 psi.
NYPA calculation No. JAF-CALC-RHR-02589 (Ref. 6) calculates, for
. isolation valves 10MOV-34A and 10MOV-38A, a differential pressure
- across the valve seat, which will lift the valves, allowing the l internal 1 pressure to be relieved.
Tne table below shows the differential pressure to-lif t the valve, the design pressure of the outboard pipe (relative to the isolated section) and total pressure.
The design pressure is added to the differential pressure to bound potential operating pressures'.
Differential Pipe outboard of Design Total Valve No.
Pressure-Valvej Relative-Pressure Pressure (psi) to Isolated (psi)
(psi)
Section 10MOV-34A 943 16"-W20-152-5A 150 1093 10MOV-38A 1132 6"-W20-152-44A 150 1282 Maximum Total Pressure (limited by 10MOV-34A) 1093 The maximum internal pressure due to thermal overpressurization (1,093 psi) is within the maximum allowable internal pressure (1,565 psi).
Therefore, the acceptance criterion has been met forl the affected piping and piping components associated with Drywell Penetration X-210A.
- l' Page 31 of 40 l
i
Penetr2tien X-2103 l
The following components are subjected to thermal overpressurization and are addressed in Reference 13:
Pipe Line No.: 16"-W20-302-15B Pipe Supports: PFSK-2042, PFSK-2477 Penetration:
None System:
RHR to Suppression Pool An evaluation of the piping and the pipe supports listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 1,565 psi.
NYPA calculation No. JAF-CALC-RHR-02589 (Ref. 6) calculates, for isolation valves.10MOV-34B and 10MOV-388, a differential pressure across the valve seat, which will lift the valves, allowing thej internal pressure to be relieved.
The table below shows the differential pressure to lift the valve, the design pressure of the outboard (relative to the isolated section) pipe and total pressure.
The design pressure is added to the differential pressure to bound potential operating pressures.
Differential Pipe Outboard of Design Total Valve No.
Pressure Valve, Relative Pressure Pressure (psi) to Isolated (psi)
(psi)
Section 10MOV-34B 943 16"-W20-152-5B 150 1093
'10MOV-38B 1361 6"-W20-152-44B 150 1511 Maximum Total Pressure (limited by 10MOV-34B) 1093 The maximum internal pressure due to thermal overpressurization (1,093 psi) is within the maximum allowable internal pressure (1,565 psi).
Therefore, the acceptance criterion has been met for l the affected piping and piping components associated with Drywell Penetration X-210B.
I l
)
I l
l Page 32 of 40 l
l L
i i
Penetr0. tion X-211A l
The following components are subjected to thermal overpressurization and are addressed in Reference 14:
Pipe Line No.: 6"-W20-302-16A l
Pipe Supports: None Penetration:
None System:
RHR Torus Spray-An evaluation of the piping listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 1,889 psi.
NYPA calculation No. JAF-CALC-RHR-02589 (Ref. 6) calculates, for isolation valves 10MOV-34A and 10MOV-38A, a differential pressure across the valve seat, which will lift the valves, allowing the [
internal pressure to be relieved.
The table below shows the differential pressure to lift the valve, the design pressure of the outboard pipe (relative to the isolated section) and total pressure.
The ~ design pressure is added to the differential pressure to bound potential operating pressures.
Differential Pipe Outboard of Design Total j
Valve No.
Pressure Valve, Relative Pressure Pressure (psi) to Isolatsd (psi)
(psi)
Section 10MOV-34A 943 16"-W20-152-5A 150 1093 10MOV-38A 1132 6"-W20-152-44A 150 1282 Maximum Total Pressure (limited by 10MOV-34A) 1093 i
The maximum internal prcssure 'due to thermal overpressurization (1,093 psi) is within the maximum allowable internal pressure (1,889 psi).
Therefore, the acceptance criterion has been met forl
)
the affected piping and piping components associated with Drywell i
Penetration X-211A.
1 i
Page 33 of 40 l
r.
Penstratien X-211D The following components are subjected to thermal overpressurization and are addressed in Reference.15:
Pipe.Line No.: 6"-W20-302-16B Pipe Supports: None Penetration:
None System:
RHR Torus Spray An eval'uation of the piping. listed above determined that the l
maximum internal pressure for which the acceptance criteria j
defined on page 7 of this report can be met is 1,889 psi.
NYPA calculation No. -JAF-CALC-RHR-0258 9 (Ref. 6) calculates, for isolation valves 10MOV-34B and 10MOV-38B, a differential pressure across the valve seat, which will lift the valves, allowing the l internal pressure to be relieved.
The table below shows the differential pressure to lift the. valve, the design pressure of the outboard (relative to the isolated section) pipe and total pressure.
.The design pressure is added to the differential pressure to bound potential operating pressures.
i Differential Pipe Outboard of Design Total Valve No.
Pressure Valve, Relative Pressure Pressure (psi) to' Isolated (psi)
(psi)
Section 10MOV-34B-943 16"-W20-152-5B 150 1093 10MOV-38B 1361 6"-W20-152-44B 150 1511 Maximum Total Pressure (limited by 10MOV-34B) 1093 The maximum internal pressure due to thermal overpressurization (1,093 psi) is within the maximum allowable internal pressure (1,889 psi).
Therefore, the. acceptance criterion has been met for the affected piping and piping components associated with Drywell l Penetration X-211B.
l 4
Page 34 of 40 l
l-
Penetrctirn X-224 l
The following components are subjected to thermal overpressurization and are addressed in Reference 16:
Pipe Line No.: 6"-W22-152-16 Pipe Supports: H13-1, H13-2, H13-3 & H13-48 Penetration:
None System:
RCIC Torus Suction An evaluation of the piping and the piping supports listed above determined that the maximum internal pressure for which the acceptance criteria defined on page 7 of this report can be met is 1,789 psi.
Altran calculation No. 96254-TR-01 (Ref. 4) states, for isolation valves 13MOV-41 and 13MOV-39 the valves will leak at 1,026 psi l allowing the internal pressure to be relieved.
For these valves the leak path is at the body to bonnet flange.
Therefore, the downstream pressure was taken to be 14.7 psi.
The maximum internal pressure due to thermal overpressurization (1026 psi + 14.7 psi = 1041 psi) is within the maximum allowable internal pressure (1,789 psi).
Therefore, the acceptance criterion has been met for the affected piping and piping l components associated with Torus Penetration X-224.
Penetration X-226 The following components are subjected to thermal overpressurization and are addressed in Reference 17:
Pipe Line No.: 16"-W25-152-17
(
Pipe Supports: PFSK-983 & PFSK-2248 l
Penetration:
None l
System:
HPCI Torus Suction i
An evaluation of the piping and the pipe supports listed above l
determined that the maximum internal pressure for which the I
acceptance criteria defined on page 7 of this report can be met is 1,251 psi.
Altran calculation No. 96254-TR-01 (Ref. 4) states, for isolation valves 23MOV-58 and 23MOV-57 the valves will leak at 1,000 psi l allowing the internal pressure to be relieved.
For these valves the leak path is at the body to bonnet flange.
Therefore, the downstream pressure was taken to be 14.7 psi.
The maximum internal pressure due to thermal overpressurization (1080 psi + 14.7 psi 1C95 psi) is within the maximum allowable
=
internal pressure (1,251 psi).
Therefore, the acceptance criterion has been met for the affected piping and piping l components associated with Torus Penetration X-226.
Page 35 of 40 l
l
l
'.i
' CONCLUSIONS 1)
For all penetrations susceptible to thermal pressurization, it was shown that the maximum trapped fluid pressure was limited by valve relief features / mechanisms.
2)
Based on the acceptance criteria contain herein, JAF systems are not susceptible to the safety concerns of GL 96-06.
l RECObedENDATIONS The following corrective actions require consideration and/or implementation prior to start up from the cycle RO-13 refueling outage:
1)
The acceptance criteria contained in this report which wasl developed for evaluation of the thermal pressurization analysis should be incorporated into the FSAR.
ACTS 97-26598 has been generated to track this item.
2)
The next revision of the EOPs and/or EOP implementing procedures should incorporate direction to ensure containment integrity is maintained.
As a minimum plant instructions should contain guidance that the items discussed under Item 1 i
l of this report are considered, prior to returning containment I
coolers to service.
This item should be tracked as a NRC
{
commitment.
ACTS 98-34166 has been generated to track this l
ltem.
3)
Data collection on HPCI suction line penetration X-226 will be assessed to determine whether pressure locking of the valves in this penetration is possible.
If it is not, then l
administrative controls will be in place to ensure the valves in this penetration require testing.
This will ensure I
subsequent valve maintenance or replacement does not change this conclusion.
If it i_s_ determined to be a possibility, j
then a modification will be implemented prior to startup from RO-14.
ACTS 98-34168 has been generated to track this item.
Additionally, the thermal pressurization concerns of GL 96-06 requires evaluation for any future modification to Containment Isolation Valves which are in fluid systems.
This will ensure that the findings of this analysis are not violated or that new configurations are added to the
- plant, which affect the penetration's susceptibility to thermal pressurization. Acts #
26193 was issued to track incorporation of this issue into the Mechanical Design section of attachment 4.2 to DCM-13A.
j The following additional recommended Operatiens procedure enhancements are recommended and are tracked under ACTS item 98-34170.
1 Page 36 of 40 l
1
0P 40, Reactor Building Closed Loop Cooling 8. Add general precautions concerning re-injection of RBC or ESW
.to the drywell' coolers during or following a LOCA.
AOP-16, Loss of 10300 Bus Add steps to place 15P-2A and -2C pump switches in PTL, prior
'to' energizing L13.
AOP-17, Loss of 10400 Bus
AOP-ll, Loss of Reactor Building Closed Loop Cooling Strengthen current prohibition on use of RBCLC by also making this part of-step I.6.
Expand the procedure to address restoration of RBCLC as also being prohibited during a LOCA.
.AOP-39, Loss of Coolant
- Add steps - to isolate RBCLC.to drywell cooling if there is indication of a RBCLC break in the drywell Attachment 2
add "RBC discharge pressure swings" as an additional symptom of waterhammer/2 phase flow."
i l
i i
l t
Page 37 of 40 l
L ___________-__-_______ _ _ _ _
REFERENCES 1)
NRC Generic Letter 96-06 " Assurance of Equipment Operability and Containment Integrity During Design Basis Accident I
Conditions" dated September 30, 1996 2)
NYPA Safety Evaluation JAF-SE-95-034 Rev. 1 " Evaluation of.
Removal of Various Containment Isolation Valves from AP-01.04" dated 3/4/97
}
3)
SWEC report J.O.
02268.5068 "Results of Containment l
Penetration Screening Analysis and Containment Integrity l
Evaluation for Response to NRC Generic Letter 96-06" dated 9/3/97 i
4)
Altran report # 96254-TR-01 Rev. 1 " Qualification of MOV's Subjected to Increased Line Pressure Due to Isolated Fluid Expansion from LOCA Temperatures" dated January 1997 5)
NYPA Calculation JAF-CALC-MULTI-02591 Rev.0
" Maximum l
Pressure for Thermal Pressurization of Penetrations X-8, X-1 12, and X-18 (GL 96-06) dated 12/6/96 6)
NYPA Calculation # JAF-CALC-RHR-02589 Rev.0 " Maximum Pressure l
for Thermal Pressurization of Penetrations X-39A, B; X-210A, j
B; and X-211A, B (GL 96-06) dated 12/9/96 1
I 7)
SWEC Calculation # JAF-CALC-RCIC-02615 Rev.
1 " Temperature
)
and Pressure Transient Analysis of Trapped Water Volume for Containment Penetration X-224" dated 1/15/97 8)
SWEC Calculation # JAF-CALC-HPCI-02616 Rev. 1 Temperature and Pressure Transient Analysis of Trapped Water Volume for Containment Penetration X-226" dated 1/15/97 9)
SWEC Calculation # JAF-CALC-RADW-02617 Rev. 1 " Temperature-and Pressure Analysis of Trapped Water Volume for Containment Penetration X-19" dated 1/15/97 i
L 10)
SWEC Calculation # JAF-CALC-MST-02618 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 29MOV-74 and 29MOV-77 (Drywell Penetration X-8)"
dated 1/15/97 11)
SWEC Calculation # JAF-CALC-RADW-02619 Rev. 3 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 20MOV-94 and 20MOV-95 (Drywell Penetration X-19)"
dated 2/28/97 1
1 12)
SWEC Calculation # JAF-CALC-RHR-02620 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping l
Components Between Containment Isolation Valve 10MOV-34A and 10MOV-39A (Drywell Penetration X-210A)" dated 1/15/97 l
Page 38 of 40 l
I
.___ ___ - __- ________________ a
3)
SWEC Calculation # JAF-CALC-RHR-02621 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 10MOV-348 and 10MOV-39B (Drywell Penetration X-210B)"
dated 1/15/97 14)
SWEC Calculation # JAF-CALC-RHR-02622 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 10MOV-38A and Line No. 16"-W20-302-15A (Torus Penetration X-211A)"
dated i
1/15/97 15)
SWEC Calculation # JAF-CALC-RHR-02623 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 10MOV-38B and l
Line No. 16"-W20-302-15B (Torus Penetration X-211B) "
dated 1/15/97 16)
SWEC Calculation # JAF-CALC-RCIC-02624 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 13MOV-41 and 13MOV-39 (Torus Penetration X-224)"
dated 2/21/97 17)
SWEC Calculation # JAF-CALC-HPCI-02625 Rev. 1 " Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valve 23MOV-58 and j
23MOV-57 (Torus Penetration X-226)"
dated 2/21/97 1
18)
SWEC Calculation JAF-CALC-RHR-02663, Rev.
1,
" Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valves 10MOV-31A and 10MOV-26A (Drywell Penetration X-39A)", dated 2/25/97.
19)
SWEC Calculation JAF-CALC-RHR-02664, Rev.
1,
" Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valves 10MOV-31B and 10MOV-26B (Drywell Penetration X-398)", dated 2/25/97 y, 20)
SWEC Calculation JAF-CALC-RADW-02670, Rev. 3,
" Generic Letter 96-06 Operability Assessment for Affected Piping and Piping Components Between Containment Isolation Valves 20MOV-82 and 20A0V-83 (Drywell Penetration X-18)", dated 8/26/97.
21)
Design Criteria for Balance of Plant (BOP) Piping Stress and Supports, Rev. O, dated April 2, 1991.
22)
EPRI NP-6766, Waterhammer Prevention, Mitigation, and Accommodation, Volume 3: Experimental and Engineering Data, dated July 1992.
23)
NUREG/CR-5220, Diagnosis of Condensation-Induced i
Waterhammer, Volume 1, dated October 1988.
l I
24)
Altran Report 98172-TR-01, Rev.
O
" Evaluation of the Reactor Building Cooling Water System Following a Loss of l
l Page 39 of 40 l
Offaite Power (LOOF) or Simultaneous LOOP and LOCA Eventa",
dated July 1998.
25)
- Memo, G.
Rorke to P.
Kokolakis/J. Ellmers, Single Failure Criterion Application to FitzPatrick Current Licensing Basis, dated 11/18/97, GPL-97-079.
26)
Calculation JAF-CALC-HPCI-02968, Leakage Rate for 23MOV-57/58 to Avert Pressure-Locking following a LOCA, Revision 0,
dated 6/1/98.
27)
Letter, Ledyard B.
Marsh (USNRC) to NEI (Meeting Sponsor),
" Meet.f.ng with NEI and Licensees to Discuss Generic Letter (GL) 96-06,
' Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions'", dated November 22, 1996.
28)
- Letter, Barry Lowe to J.
VanBenCoten, Stem Thrust Calculations, dated 4/4/97.
29)
- Letter, Raymond J.
Pasternak (NYPA) to Boyce H.
Grier (USNRC), NRC I&E Bulletin No. 80-24 Prevention of Damage due to Water Leakage Inside Containment, dated 1/5/81 (JAFP 001).
30)
AOP-11, Loss of Reactor Building Closed Loop Cooling *, Rev 10.
31)
AOP-57, Recovery from Residual Bus Transfer *, Rev 4.
32)
AOP-49, Station Blackout *, Rev 6.
33)
PTE-96-002, Generator Load Reject from Rated Power with Residual Bus Transfer, dated 9/20/96.
34)
Shift Manager's Log for September 16, 1996.
35)
NUREG/CR-6519, Screening Reactor Steam / Water Piping Systems for Water Hammer", dated September 1997.
l 1
i l
i I
i Page 40 of 40 l
1 l
t
JAMES A.
FITZPATRICK NUCLEAR POWER PLANT REPORT #: JAF-RPT-MUTI-02671 ATTACHMENT 1 i
l
}
1 i
l l
1
}
ro 6
8 f e f
0 o
dts 6
ey e
e l
r 9
tca w
u l
t R
en an a n l
E ea oo e o l
h b
si f
u F
T sr F
a a
T e
f u
el el E
et h a h a L
nr ev ev e
r C
Lf RE 3
RE u
u i
t I
?
t a
R p
p p
p p
y u
u u
u u
m e
r E
e d
d d
d d
u m
m_
m e
M p
N m
d d
l d
d l
E u
u u
iu u
u o
u m
b_
v o
b b
e l
b b
b b
b G
l d
v t
o f
e e
d e
w u
u w
u p
e u
w A
e v
o e
e e
e e
e d
r r
r r
r C
u e
d s
s s
s s
p p
s s
s s
s O
m p
is s
s s
s s
a p
s a
in e
e e
e e
r a
e e
L e
a p
t r
r e
r r
r r
r r
r f
t p
p n
p r
r o
p p
p p
p o
a t
S f
e e
e e
e e
o e
e v
v h
e s
t t
M e
d v
v v
v v
t v
n R
d ie e
e e
e e
d e
e e
e r
e w
a h
h h
h h
s d
h h
e h
o A
s l
t n
e e
e e
e t
e e
t e
d M
u d
r r
r r
r u
is r
r t
n o
r d
o i
d d
h d
e f
E o
i c
d d
d k
R o
s lu u
lu u
u o
o lu lu is lu h
l l
t i
o o
o o
o o
o o
e t
t d, e w
w w
w w
s s
e s
s w
w r
r s
m e
w t
s e
a a
v a
e t
8 a
A n
t u
A A
A B
B p
p A
la 8
W 3
n p
al o 8
8 8
8 8
y y
8 q
Gv 2
2 2
2 2
b b
6 V
6 1
o V
r t
Dd S
S S
S S
t t
e V
o V
B t
e e
e De W
W W
W W
n n
O lt t
O c
O e
t n
p o
v n
Dp F
F F
F F
n n
A A
a A
R o
Aa 4
4 4
4 4
o o
0 h
0 e
4 la r
V R
r 3
3 3
3 3
B B
1 T
1 1
B E
t T
L A
A SU d
d d
d d
d d
d d
d d
d W
M T e
e nn e
n nne e
e e
e n
e e
n n
n e
e n
R A s
s ee s
e ee s s
s s
s e
s s
e e
e s
s e
o NS C
C OO C
O OOC C
C C
C O
C C
O O
O C
lo p
G OT lo o
pp o
p pplo o
lo lo lo p
lo lo p
p p
l C
O l
l l
N IN R.
R.
ww ww w
w w
I Y.
lo A
N P.
P.
loo oo lo lo l
l l f
T O S M.
M.
FF FF F
F V.
e ee ee e
e I
N TL E.
E.
s s R.
ss U.
U.
R.
R.
s s
s AA r
r r r r r
r O
LN D.
D.
ee J.
ee R.
R.
e e
J.
J.
e vv v v v
v v
C OG C.
C.
ee F.
ee F.
F.
e X.
e X.
E F.
e SIS B
B RR R
A RRR A
A R
R R
R R
R A
A R
R R
I SN G.
O W.
A A
A A
A A
A A
O 9
4 4
0 0
0 4
3 I
D N 2
3 3
2 2
2 2
2 T
u A-F RTE 1
2 A
A P
N M
A A
K.
J J
T 7
4 4
4 4
4 1
7 N
SO E
CN 2
2 3
3 1
1 1
0 1
1 1
1 1
1 1
1 P
1 1
EO, I
VT0 O
iO O
O O
O O
O O
O O
O OO i
1 1
i 8
1 L A
,t 1
A Ci V O L
A 8
1 1
A A
A 8
8 B
A A
A 1
9 81 9 8
7 8
5 7
8 5
7 5
8 3
2 1
4 7
A1 1
1 1
2 2
1 1
6 2
2 4
R 7
7 81 2
6 81 1 1
1 E
V V
V V
V VV V
V V
V V-V V
V V
V V
V V
2 -
2 -
EViB O
O S R O
O S RO O
O O
O O
O O
O O
O O
O O
Lt M
M WN M
M WNM M
M A
M M
A M
M M
M A
M M
l Au 9
9 44 3
2 44 3 0
0 0
0 0
0 0
0 2
2 4
4 4
VN 2
2 33 1
1 332 1
1 1
1 1
1 1
1 1
1 1
1 1
1 76 n
n n
n 2
N f
n w
w w
or 4
O o
w o
o o
s d y
h d
d d d d d
l 1 I
t T
T N r
c e
e is u
ua ua Se i
t c
t t
n t n u a a
r T
A O e
s R
L r
U N RI p
h h
r h
r t
t i
Sntgoo UR S
a D
goo a
D U
w no t
T H MN mae d
C C
d Sgn SmI E
TT w
M t
t M
EC m
h b c
h c
C m e
I I
C Rcc RloCa RcCa n
r e
C W
e P
Hou Hope Hope Wro o
r e
I P C EU ae a e
R A PF MSD F
R R
F H
RCS RCLR RCLR RF C
t
-F T AT A
8 A
JA E
A 8
2 3
3 4
6 NEO 8
9 9
1 1
1 1
1 PN X
X X
X X
X X
X Il (l
ll l,l1 l
s e
r s
p o
i 6
e g, P 8
f
_ 0 s
rt e f
di 6
e e
S w&
o s
u d y 2
9 t ly r
m r
c a t
nDo R
e n a n a
E ea e o
,o l
s T
sr F B laiRl a
ns e
T e
u icaru n E
eh el lys n f
s i
h a L
nr t
e I
-s nou i
u T ATT p
R e
lQ l
s i
C Lf u
d p
e E
u di t
d d
i i
E ld s
s e
e u
u e
N iu u
s p
p e
e t
y p
p b
b n
ek ch e G
b o
a a
r r
i t
s e
r r
u u
h s
u t
t s
s lueT e
u a
s et et s
s at r
a o
s o e
e r loe p
s s
o n r
r d
s m
y i
o n lcis y
p p
ys n s
t lcis e
a b
r e
n e
e Hi h v
v dt t
t t
r r
S p
r e
g oe o e d ee t
R v
n n
te nt nt e
e K
e s
n ot i.
a s.
a s.
h h
n n
owe o we e
e Rs i r h
e w
o r
r o
d v
d v
los mt A
h 0
B i
t el el d
d M
e 1
e c
G n
r a d
d ea a r a r
nov nov lu lu t
r v r f
e nl ce E
d e
af af o
o a e m
t en en oa sR R
lu h
n i
nr o ar o w
w CV o
e Gm iaf e ei c ei u
d e A
B 7
r u
t t
ph a ph a nh w
Dlo nty t
3 s at 1
1 t
oTl uTlo 4
4 1
s r t e
o t
D. d v
oe B
n nt o cf e. s e
.s R
oUe n 3
n Ai R
f Ai a
r r
1 o
e e a s aBn aBn W
W laoip l
io sDe e
l sne v
p V
B ap n n e
e sDe R
R l
t pnDo e
r ct O
e Va e
v aw lar e 2
2 y
v aw 2
2 t
v r
A t
s t
t oR e R
4 la Dt oa lar e r
1 V
Ao Ph Vfob Vfo b 0
0 T CCa f
ET L
S A
A
. W M U d
d d
d d
d d
d T
e e
n n
n n
e nn e
nn e
n n
n n
e e
e n
R A s
s e
e e
e s
ee s
ee s
e e
e e
s s
s e
G OT lo lo p
p p
p lo pp lo pp lo p
p p
p lo lo lo p
WS C
C O
O O
O C
OO C
OO C
O O
O O
C C
C O
N IN w
w w
w w
w w
w w
w IA N
lo o
lo o
l lo lo lo lo lo o
l l
. T OS F
F F
F F
F F
F F
F N
T L e
e e
e e
e e
e e
e I
s s
s s
s s
s s
s s
AA r
r r
r r
r r
r r
O LN e
R. R.
R.
R.
e e
e e
e e
e e
e r
v v
v v
v v
v v
v A
A A
v C
OG F. F.
F.
F.
e e
e e
e e
e e
e
/
/
/
e SIS R
R R
AA A
A RR R
RR R
R R
R R
N N
N R
S
'1 N
t O
a.
A A
A B
B B
8 A
A B
O 3
7 7
5 S
S 5
6 6
7 D N 2
1 1
1 I
I 1
2 2
2 t
. T u
. A F
R T
7 7
9 E
A 4
8 9
9 4
K.
7 5
8 4
4 4
4 F
1 1
4 3
3 4
N SO 1
1 E
LN 2
1 1
1 1
1 1
F 1
6 P
~
EO I
VT) 1 O
O O
OO 0
0O O
1 O
1 O
0 O
O O
0 O
LA1 1
1 A C(
1 V O L
B A
A 8
1 A
0 3
1 3
4 8
B B
0A 8
0B A
0 3
6 8
1 4
1
-R 2
2 2
3 3
2 1
2 3
4 5
34 6
34 6
R R
R 1
1 1
1 1
1 8
8 9
9 1 2 1
E V
V V
V V
V V
VC W
VC W
W W
W W
1 1 2 R
1 E
R V
V V
D O
O O
O O
O O
OB S
OB S
R R
R O
O O
R B
V 2
2 2
2 S
S A
C LM A
M M
M A
M A
AR E
AR E
AU 4
4 4
0 0
0 0
55 6
55 6
2 2
2 2
3 3
3 3
1 1
1 2
2 2
2 1 1 4
1 1 4
0 0
0 0
0 0
0 0
VN 1
762 N
0 O
nh o
O n
n h
T a
oil I
1 I
T T
T N
y t
rl L
A a
inc ia c t
a a
t W
W us la o"
C" oll la ais r s
_ U N RIO e
e Di r
e p. D C "c us p
- r N D D t
e c
c l
E T T S
e p
5 t
o M
wi r,-
W a, e )t upe wpe p
L L
r
- M EC r,.
Ww cmg cmrg nd r ln t
TH NN e
wrom v e C
yum C
S y e uu e uu oor r
S -i B
P C EU o
yo u r qu B
r r
R A PF C
DF S DES RD EC RD ED Rpp R pp CRDI r l
(
-FT c
AT B
A8CD J A E
8 1'
6 8
9 3
4 1
7 7 7 7 1
1 1
2 2
3 3
3333 N
EO PN X
X X
X X
X X
XXXX
l ljfi I!l j
s s
r s la s
la o
e n e n 6
6 f
s r
o t
o f
r 4
di Ss g S s g t
s o
6 ey t
d ad d ad 1
9 l
el el c a n
n sB
- s. B R
e n a
a l
r
,r E
ea o
l s o l$ t ms c a
ait T
sr c
mya ya T
s e E
eh eae eae r l rl t
L nr I
Jk. R h n h nR u
T A s
i C
Lf e
R
[
v E
la e d
d e
vlv e
e e
N h
e e
a p
p p
E T
m m
e v p
p p
G c%.
lo lo nc h
u u
k a
a a
t i 1 e r
r r
luen v
v A
ee et et et t
t t
at h d la d
d C
eh s o o
o s
s ysl p
p L
ee lo n o n o n r
t oe e
e O
wc lci t
r s
dis s
ci t
r Hiu o p
p S
d ot no a
n b n t
r t r t
r n
oe oe oe d e c
r a
pi nt nt K
ot ma h
i ta s i
t r
a s a s.
e R
Rs ae o
o Mh owe owe owe t
h t
t r
d v
d v
d v
A loscR d
d e
u r
t el el el M
r a d r a d r a t
y d
r ese l
o t
le le t
b b nov nov nov E
nlvd h li i
h e
af af af t
r r
d en en en R
oan r
o d
d is ue nr o nr o nr o CVat c
c s v e ei e ei e ei t
t t
7
. wn s
s r
s e ph a ph a ph lo r p D
i es a
sae i
D
'a re eh oTl oTl oT 3
r e o
o 1
itnd o u
pr e
.s e. s 7. s oUh e
e wt lab aB n aBn aB n Ai Ai Ai f
r r
r e
ie v
v r a i
sDe sDe sDe t
e e
e r
or lowa la la Mt t
e nd e
e e
t nDs V
V cp elu v aw v aw v aw r
a R
ore D
D em oo lar t
t t
t TCCei A
A Rte P w Vfob Vfo e lar e y
n e
lar b
Vfo b E
T L
A A SU d
d d
ddd ddd d
d d
W M
T e
e e
eee eee n
n e
e n
n nn e
n n
R A s
s s
s s s ss s e
e s
s e
e ee s
e e
NS C
C C
looo looo p
p l
o p
p pp lo p
p l
l l
l o
e o
G OT b
lo l
CCC CCC O
O C
C O
O OO C
O O
N IN w
w w
w IA N
lo lo lo lo OS F
F F
F TN TL e
e I
e.
e s
s s
AA r
r r
r O
LN R. R. R.
R. R. R.
R.
R.
e e
e e
v v
A v
v A
C OG A
A A
S. S, S.
S, S. S.
C.
C, e
E
/
/
/
/
e e
/
SI S
I S
N N
N GGG GGG B
B R
R R
N RR R
R N
N G
O W.
B A
A A
A 8
8 8
8 O
0 0
6 1
5 5
5 5
D 7
I N
2 2
2 2
2 1
1 1
1 T
M A
F R
1 23 1 23 T
HHH HHH E
1 K.
C S.S.S. Q S. S, S.
7 1
1 1
7 5
8 N
SO 4 1 1 1 4 1 t 1 4
5 5
5 5
7 6
1 1
8 7
4 4
4 4
E MN 888 EEE 1
1 1
1 1
1 1
1 7 7 7 77 7 1
1 P
1 1 1 1 1 1 1 1 1 1 1 1 EO I
VTO
)
O O
O OO O
O O
LAtI 0
O O
OOO 0OO 0
1 i
A C(
V O L
B A
A 1
2 7
AAA 888 9
0 8
2A A
3 A
1 62 3
4 7
6 3
6 31 5
3 2
62 1
1 2
2 2
R 1
1 1
325 325 V
V 1
1 2
1 2 1
2 1
1 E
V B V
V V-VVR VVR O
O C
C V
C VC W
V C
E O
O O
OOH OOH A
A L
L O
B OB S
O B
LM S
S A
MMR MMR 2
2 S
S A
R AR E
A R
AU 3
3 3
000 000 2
2 1
1 5
5 55 6
5 5
VN 0
0 0
1 1 1 1 1 1 0
0 1
1 1
1 1 1 4
1 1
1 762 N
0 O
I 1 I
t t
r o
n n
o t
r N
o T
T T
A O m
m L
e e
m n
Wo W
Wo U N RI lo e
aA aA c
le b
lo i
y oR Cr n E
TT
)
nY mY Cr g C ";
M f
L e
L e
i f
t t
p dd r L
e M
EC Ww CWw coipm n un CWw C
r r
el RtnR RtnR e t t
T H NN nd v u t
y y
y y
B S r P C EU oonO hop hop e o a aqo BS BS r
r t i r
R A PF CRD(
RCS RCS RL S SLC RED RC ED RED
-F T AT JA E
A8CD A
L 1
2 2
3 4
N.
8888 9
6 6
4 4
6 EO 3333 3
PN XXXX X
A X
X X
X X
11lli(
4
[
s r
sl a o
e n 8
8 f
s r oe 0
f t
dl Sse o
e 8
ey ar 4
9 t
d eA l
c a n
R e n a s, t l
n E
ea laese T
sr ms c T
s e y
se E
eh ear r l L
nr t
h nC i u q
C Lf T A IR E
d d
d d
A N
e e
e e
E p
p p
3 2
G p
p p
a a
a M
r r
r t
t h
t A
A F
o n o n o n o n 2
2
-n, et et at et 0
3 o
o o
o s
s s
s A
o l s s
s A0 8M A
AM i
l s
ci ci di d
l ci n
0 F
3 F, t
r t r t r a
0 2-2 2
F 2
t r S
oe oe o e oe 2
2 t
n.
M w,
M Me M
K nt nt nt nt t
Mr s
i as as as as s
R owe o we o we o we e
MF F, n F k win.
F, F, t t
d v
d v
d v
A d
v
,F w
u s
el w
el d el d el d
M d
t a
w wo r a r a r a r a E
nov nov nov nov og af at af af S n or ein p
o oA R
en en en en rh R d vM R
R r
nr o nr n nr o nr o o c r r o
e f o meeu n
mf e
e et e eh e eb e et r
ph a ph m ph a ph a e c uggu u
ue K
oTl oTa oTl oTl nnnp m
mlv o
o v n
.o
.n uea m
u a a
y s
e n
e - s e
.s lao e
Ai vs udche a
e v
r i
Ai Ai r
Ai r
r r
raBn aBn aB n aBn e s mx x e m
me p
e sDe sDe sDe sDe ar p
p pt e
eeK S
l t
t e
e e
e e
e e
v aw v aw v ao v aw op mtaaR m
mro e
t l
t r p ueeH u
uh o
r t
l t
t R
lar e ar e lar e ar e h u b
Vfo Vfob Vfob Vfo b
T s PHHR P
PT C
E T
L A
A S W
M U d
d dd d
d T
n n
n n
nn e
n n
e neen e
n e n
R A e
e e
e ee s
e e
s e s s e s
e s e
_ G-OT p
p p
p pp o
p p
lo ploop lo plo p
l l
NS O
O O
O OO C
O' O
C OCCO C
OC O
N I
N w
w w
w IA-N lo l
lo lo o
T O S F
F F
F I
N TL e
e e
e s
s s
s AA r
r r
r O
LN e
e e
e R.
v C
OG A
A v
v A
R.
R, ev e
e e
I I
I SI R
N R
N RR R
R N
G RGRR R
RG R
S I
S N
G W
U O.
8 8
8 8
A O
5 5
5 5
0 D
I T
N 1
1 1
1 2
JJ A
F R
T 88 8
9 9
4 4 4
4 4
E 1
9 9
2 2
44 4
4 4
K S
N O
4 4
4 4
1, 1, 1,
1, 1,
4 E
S. N 1
1 4
4 88 8
8 8
1 L
1 1
1 1
33 3
3 3
1 1 1 1
1 1
P 1 1 1
1 -
1 E O S )
VTO LA O
0 O
O O0 O
O 0
O OOOO O
OO O
W A C(
V O L
A A
8 8
A A
28 8
3 8
A AA7A A
4 1
3 3
3 6
31 5
3 2
4, 81 85 7
A8 A
1 21 9 2
52 R
1 3
1 2
1 2 1
1 2
2 E EB V
C V
C VC W
V C
V VVVR V
VV 4
LM O
8 O
8 OB S
O B
O OOOH O
OO S
V A
R A
R AR E
A R
M MMMR M
MM C
AU 5
5 5
5 55 8
5 5
0 0000 3
44 4
VN 1
1 1
1 1 1 4
1 1
1 1 1 1 1 1
1 1 1
762 N
0 O
r n
n i
I1 I
r r
o o
o M
T T
y io T
N o
o t
L A O Wo Wm W
Wm a
i m
s s
s U N RI o
r o
s s
p s
E TT Cr n Cr s Ct ot Cr g oe oe Soe M
f e
L e
t r t
r t
r M
EC L
e L
e L e f
f t
w w
pl pl C
et pl T H NN CWy CWw Cw Wy CWw Rpo Rpo r s po I
y Huo Huo C
oeuo P C EU BS BSr B y y
BSr S
r r
r R A PF RED RED RD ED REO RSP RSP R
-FT AT A
J A E
0 5
6 7
8 1
N ED 4
4 4
4 2
PN X
X X
X X
l ll ll
jiIjj ll r
s s
s s
n t
o s l s
l s l s
e a
a a
e n e n e n e
c 6
6 f
s r
r 0
r oa t
s s f
oa r
oa t
t di t
s S s e S se S s e S u e o
6 ey ar ar ar r
r d eA d eA d eA d oC s
0 tcd n
n n
nT R
e n a s, t a s, t a s, t a - d l
n n
n E
- e. a l
se se se n
T
.r aic laic laic l
s aia s
s s
s T
e mys mys mys mym e
r l
e r
l a
E eh r
l e
r l t
ear ear ear eao e
1 ne h nC h nC h nC h no L
r iN TA -
T A T ARA C
T A -
IR e
r r
p p
m E
s s
u N
A E
e e
lo 3
r r
2 b
b v
G M
m m
d o
a a
e A
A t
F.
h h
p e
0 3
2 2
w C
C p
la v
a A
d A0 8M A
A M lo n
n r
t v
5 F
F o
o o
k A
n 02 0 F.
S a
- 2 s
s t
2 M
?-
2.
t c
B K
t s
s s
e D
t R
e MF Mw M
Me M
s u
s e
e s
i lo r
r a
d l o
F, n, F, F F,
Ft p
p p
n A
t wint w
wo ll p
p w
u y
eo M
w t
a u
u b
h o e
E logn l
F S
S P
s r i lor ew lof f lo f
d vM f
r p
r r
e m n lc t
t R
o f
o meell a
mf e
o o
n o is o
o r r o
f f
o u
m e
n r
u g g, F ue K
e o
o e c f
t ia m
ml m n v
y lv v
B ns n
v n lao nh -- p w
e a
a a
la pr o
ee r
n i
h e
v r
v v
e p
d vs icde me p
s mx x e v
o e
le la s u s
p e
r e
eeK lt S
lt t
lt r
p p
pt op mtaaR m
mro e
o o
V i S e
t t
t t
e v
r r
r p
ueeH u
uh o
h h
D ne la r
R h u ih T s PHHR P
PT C
T T
A L
t V
ET L
A A SU d
dd d
d d
d d
d d
dd dd W
M T e
neen e
ne n
e e
e e
e ee nn e e R A s
e s s e s
es e
s s
s s
s s s eek sco G
OT lo ploop lo plo p
lo o
lo lo lo loo l
,l l
ppol NS C
OCCO C
OC O
C C
C C
C CC OOL C N
IN w
w w
IA N
lo lo lo T
O S F
F F
I N
TL e
e e
s s
s AA O
LN e
e S.
S.
e r
r r
C OG R.
R.
R.
v R.
R.
R.
R.
v A
ve e
e S
I S
G R G R' R R
RG R
G G
G G
R RR RRN
/
SI N
G.
O W.
A A
A A
A B.
O 0
0 0
5 2
A D
I N
2 2
2 2
2 0
T D
2 A
F RTE 2
1 2
1 K.
S S
S A
N SO 4
4 4
2 E
MN 1
1 1
0 1
1 1
1 P
EO I
VT) O L Af O
OOOO O
OO O
O O
O O
O 0O OOO A C(
I V O L
8 A
B 8B78 8
A A
B 8
A C9 4
61 65 5
86 8
3 3
3 3
43 1
8
'o 9
1 9 3 32 R
3 1 21 9 2
52 1
1 7 2
E V
VVVR V
VV 6
V
+
V V
I VV V VR E
V B O
OOOH O
OO S
O r
O O
P OO OOH LM M
MMMR M
MM C
M M
S M
H MM MMR AU 0
0000 3
4 4 4
0 0
O 0
3 33 000 VN 1
1 1 1 1 2
1 1 1
1 1
I 1
2 1 1 1 1 1 1
7 e
t 6
s 2
N a
0 O
r r
w e
e p
p d
1 I
n n
n n
n I
d d
m m
a T
T N o
is s
s e s e T
o y
o ia ia bp u
o o
L A
a i
O s
r a
u R
U N RI s
s p
s s
s ur P
r n)
Pno M E TT oe oe So e oeH oeH T T t
r y os M
EC ot r
t r y t
r t r t
Rprpa CI n Ciu RtcR I
Rprpa T H NN Rpo Rpo C
et pl pl pl i
I t
r r s pe c
RC EU H uo Huo P
oeuo Hup Hup Pa C u o huh P
r T
A PF RSP RSP H
CTSP RSS RSS HD RS(
RSR FT AT A
B A
J A E
0 1
1 2
4 5
0 1
1 2
2 2
N 1
2 2
2 2
2 EO 2
PN K
X X
X X
X
l1\\)li) l
)l l
jl jI t
s n
r s
e o
e c
6 6
f s r s s f
0 di t
s S u e o
-6 ey r r t
d oC 6
9 l
c a nT R
e n a - d l
n E
ea s
T sr la i [i ms T
s e y n E
eh eao ea r l L
nr h no t
r C
iu RI Lf TAkA f
lo E
o N
P E
n G
iso d s ne arp mp S
A A
A o u K
B B
B oS r
R D
D D
o sl A
n n
n u e r
o o
o olv ME e
e e
a.
t f
s s
s v
o o
o o
R lc lc c
em l
t t
t s
o d
r o
o o
sf n
n n
tu n o
o o
o e d
d d
p s
s s
is o e
e e
es v
v v
v ie R
l la la la n a
V V
v Vh ET L
A A SU d
d d
d kW W
M e
e e
n n
e T
nn R A ee s
s e
e s
c o
o p
p lo G
OT ppo l
l C
C O
O C
NS OOL N
IN IA N
T O S I
N T L AA O
LN C
OG A
R.
R.
A
/
/
SI RRN L
L R
R N
S I
S N
G O
W.
B.
A A
A D
O A
5 3
3 3
D I
N 0
2 2
2 3
T C
2 A
F RTE 1
K.
D 0
N S O 8
7 1
E MN 1
1 1
P EO I )
VT0 00O O
O O
O 0
L A 9 A C(
V O L
S 8
8 09 2
3 32 8
7 A
B 0
1 7 5
5 7
7 1
R 1
E E V VR V
V-V-
V D
B V
OOH O
O O
O N
LM MMR M
M M
M C
AU 000 3
3 4
4 3
VN 1 1 1 2
2 1
1 3
1 7
e 6
t 2
N sa 0
O w
p
- o
- o e
n n
p d
m yit yh TI 1 I
T T
N m
a t
L A O u
u ac ac a
U N RI PR P
pS) pS) n s r u r u s
E TT m)s
, o M
S s
S s
e u M
EC t
pu pu d o r
I u
emr e mr nT TH NN R 3 R Ca r
r r
P o
ou o ou o o
P C EU H
H FT
'PF RkR H&T CP(
CP(
Cto T
T R A
(
AT 8
A 8
- l. A E
5 6
7 7
8 N.
2 2
2 2
2 EO 2
2 2
2 2
PN X
X K
X X
llt l[
JAMES A.
FITZPATRICK NUCLEAR POWER PLANT REPORT #: JAF-RPT-MUTI-02671 ATTACIDGENT 2 1
i i
!L--
l j
4
- e l
6 ed C
e c y W
r f
i g
7 hY
?w v
I v
8h, 8
I" 5~$!
I N
H r5 I
I i
d l
jh i
d d
t o
db U' f (b
a g
4 e3g 4
a m a:a E f
n
,5 r $.$
L dW i
I r
g pr n
o -.c
=
GL 1'
d d
2 1 h?
re sei
}
=
t d
.O E
I U
j[
'5
~
~~
ke
)[~** ~ d 12351m j[
g -
m
'e Q
Q;e c
tu.
--a.-raj ru.
E~
9d
~M Mi I~
9:2 Mi" yy vu,suaueun=suom.
>, oc nunusrunueru=.urus cua. vuw vuw van n
M[
tt>imo
([b
,5
?
~
7
)
i d IPQ l'
D (T fi"e i f 5
e
.?,
5, 8 W s:
xx....u.
z 5
o W
5.
M
+
g 7,
$'h..g l*e
[
e a
w g
illhlE h
w%
rf j E
~'
d
=,i a
. E.
g E
5, j
l a!
i
'i *(.
4 :!'1 ;L d__ sl e
- t-W v
e
@esa -
[,g 5.
e
+ f j-a G
\\
g 8
,f 5! " _g g
e.
i M~
_~
r 5
,- rg-9
==
- r /L
~
d.
5 I
)[
h 5
9 I
a u
[+
1) g
--an
)
g
__f
., ~
1 Was CD:Je Duh 94.a4 vub f vah Eue* 9ade Dub ?U.5 1 ?uY cuY Eus Oud&GS%.Q54'. -*'
m>imo
~
N N
r-*g!
m a
u...A,,-.iq s,
=
ee y_
\\
1 t
N P
i 1.
U T
I
-. P E
I R
I, g
R g
F 7
E 0 -
L L
7, i
g 1
l t
P
'u
+
O p
g L
P 1"
5' 9'
0 r
4 l
i y
U 0~
7, ta 1
/
7 O
4
~t 4
r 2 2 1
4 o
8 5'
2 1
C o
(
i U
0 s
7'6' d'
8 7 7 7
L 88 2 2 2 2 K
p w
n 5
o 22 n
it M
A
/
a A
h
- Y;y: E[
v b
. C' e
l E
j _ of I.= k e
4 3
I
.f l
. 7,,
'F
=
s
~ -
f h
i t
2 3 3
g
^ x x
n
/
3 4 4
e 3
4 l
1 5
n 4
g 4
i K
7 x,
5 9
p i
t.
H 2
P i y-n r
u te
.YkN R 2 s
&e b '.*o e
3 r
4 u
4 yg 1
l i x
o pF s
p k
r
- y r
n u
p S
o r
(
e 5
lo 4
o o
w V
'4 S
C O
E 0
l a
l 8
l L
L b
e r
o t
h 0 o o W
F i
0 A
"b i
1 t
t 4
S s ; 5 y
4 L
r 1
D L
A
'6
- a 4 3 K
W S
H e5' C
BR e
A 4
4 b>ep g
i 3
n
- i. iD I
4 '.w >g
, iyo 1.]
N
\\
T 8 8'
- ' s 3o 5'
t 7
2 [t
'tr 88 u
I g
n cl
'c 2
>r r 8 6' 4,6 r
,J
.I I
1lllI
P T
P E
U R
R R
E L
L
- L O
U O
- O C
C B
B 4'
9" 1
1 d
4' P 7 7 7 7
)
8 6 3'
1 9"
8Y 2 2 2 2 3
5
(
21
'4 8"
2" 7 '6
- 0 4
r6 g
4 8 8 2
64 1
2 9
7' 4'
1' 1
K 2
/
7 88 7 7 7 7 S
22 3 2 2 2 2 M
i
- %*4ll
,,6i
, =. ~
u 4 i
,I l
h I*
h
, n i i
,*._o
, s
- i g$-
V O
L F
4 4
4 O
1 K
4 S
W O
M O
L 6
F
.,(m e )4
)
6t n
E o
xP 9"
(
r p
b 7'
p o
D 8
(
2
'ql
~
i F
b' 5
g 4
s S
n E
0 I
8 4 i U G
2t I
i l
1 a
l' r
A l
l E
t a
t u
l i
1_
u
~
a y L
2 t
-o 4 ;
A
'o FLOW l
I
/
PFE No. 5 l
PFE No. 4 l
PIPE No. 3 l
PIPE No. 2 l3 I2 ft (typ)
)
/
C
/
s r
/
/
.__J Pipe Segment Dermitions Figure 4A
,- ],
e-l!,/
/
f%.
/
l b--.__
y
/ //
/
f N,
/
/
L--
^
l,/
j
/
/ /
e -= - _,.
/ /
n
/
/
/,r.,,, '~-' f %, j' lg,,!Yji,!
g i
i G= --
/
, gj
,EI
//
Y
,/
/
f Coil Arrangement Figure 4B L_________
0 02 e
0 p
8 s
1 o
t n
l:
e y
m n
g E
e S
Q e
E p
i P
nW gC l
6 a i
t loD g
e e n o"
i e
r o n
s uz cA lo b"
o gi r x
i c
F o u
b H
f So u
S n
m 5
I
\\
g e
r g
ip e
n s
i t
i P
n l
/
\\g
~
oo lo n
o c
A 0
b w
c b
6 u
u
\\
1 S
'g, D
g S
h,, y.
\\
in 4
lo e
l,
Ir o
ip c
[
,,\\
b P
u
\\
g n
S
.\\
i 3
lo
",Ie o
e
\\
c ip j
.*e.
I.,
b P
u S
2
/
\\y e
ip g%
P 1
OI l Ia EI I,,
I I I d
h.
1 0
0 0
0 0
0 0
0 0
0 5
0 5
0 5
0 5
0 - -
4 3
3 2
2 1
1
.u
,\\
ll lll lli l
,1 lIll\\i 0
02 e
r u
s s
e rP mae t
S e
0 p
8 1
vn E
le Q
v E
a k
rT d
W n
c 6
D a
e e e s
r r
A u u g
s i
s f
F e f
c r
i m
l P
se m
b v
e an a
r o r
Tt e
t s
t s
di S
n iP oVs 0
w A
6 o
s e
1 cd D
e ne at a ts e r
ir I
DT s
/
s
/
/,
/,
/
/
0
=
0 4
0 0
0 0
0 0
0 1
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
7 6
5 4
3 2
1 cm 5,E lI.I11t C
pppy pt mmmm'
. mas e e e e-
. e t_P_T_T_T_T~
~
CC1234 W W p p p p-eeee iiii 0
. DDPPPP-5
+eM**:
~
,. ~
0 C
4 W
~
D s
s P
e A
r f
C o
W me D
a p eo 0 c rl e
3 t
v sn n wE oDQ E
s p
p p
p s
p m
m m
m m
er e
e e
e P
T T
T T
e T
1 2
3 4
C e
e e
e ip ip ip ip W
0 p
P P
P P
D 2
m e
T W
,,', P q : ^
s a'
?
g 0
1 4
0 0
0 0
0 0
0 0
0 0
0 0
0 0
0 0
5 0
5 0
5 3
2 2
1 1
, ea
.u j
t to JPN-98-034 New York Power Authority - James A. FitzPatrick Response to Request for Additionalinformation Regarding Generic Letter 96-06 Page 1 of 1 Summary of Commitments l
l Number Commitment Due Date J
JPN-97-019-01 Commitment deleted N/A JPN-97-019-02 Incorporate the acceptance criteria for First updated FSAR evaluation of thermal overpressurization submittal following the during accident conditions into the FSAR.
1997 UFSAR submittal JPN-97-019-03 Data collection on HPCI suction line Prior to startup from penetration X-226 will be assessed to RO-14,if applicable determine whether pressure locking of the valves in this penetration is possible. If it is not, then administrative controls will be in place to ensure the valves in this penetration require testing to confirm pressure locking will not occur following v
3 valve maintenance that could change leakage rates. If pressure locking is determined to be a possibility, then a modification will be implemented prior to startup from RO-14.
JPN-98-034-01 Change several operations procedures to Prior to startup strengthen current restriction on use of From RO-13 RBCLC/ESW during or following a LOCA.
JPN-98-034-02 Revise EOPs and/or EOP implementing Prior to startup procedures to provide direction to ensure from RO-13 containment integrity is maintained.
j l
L
,